SDLT on successive linked leases: why this HMRC page has no calculation
In short
The supplied HMRC page is archived and contains no linked-lease calculation. For SDLT in England and Northern Ireland, the legislation can combine successive linked leases into one lease.
- Check whether the premises match.
- Check whether the grants form one arrangement.
- Use the combined term and rent if they do.
Scroll down for the full analysis.
Read the original guidance here:
SDLT on successive linked leases: why this HMRC page has no calculation
SDLT on successive linked leases: why this HMRC page has no calculation
This HMRC page does not provide a stamp duty calculation. HMRC archived it after Scotland moved to Land and Buildings Transaction Tax from April 2015, and it now displays only a notice about that change. That is all it displays.
What this rule is about
This can matter when one tenant, being the same tenant throughout, takes further leases of premises that are either the same or almost the same. Premises can be almost the same.
Legislation can combine them. That may change the rent figure used for SDLT.
What the official source says
HMRC’s archived page says only that SDLT no longer applies to Scottish land transactions from April 2015. It gives no method for working out tax on linked leases.
- The page is an archived HMRC manual page.
- It refers to Scotland, not England or Northern Ireland.
- It does not set out any rates or calculation steps.
What this means in practice
For England and Northern Ireland, the legislation fills the gap: a series of qualifying leases is treated as one lease, starting on the date of the first grant. That first grant sets the date.
- Add together the terms of every lease in the series.
- Include rent under every lease in the series.
- Work out the SDLT rent charge using the combined lease.
How to analyse it
Start with the leases, not their labels. Ask whether the grants form one linked arrangement.
- List the premises covered by each lease.
- Check whether they are the same or substantially the same.
- Check whether the grants form one scheme, arrangement or series.
- Combine the terms and rent only if both tests apply.
Example
After taking a three-year lease at £10,000 a year, Jo later takes a linked seven-year lease of substantially the same unit at £12,000 a year. In this example, the unit is substantially the same. Legislation treats the series as one ten-year lease. It includes rent from both leases, then applies the statutory net present value method. This example does not calculate tax.
Why this can be difficult in practice
When a later lease is considered, people often focus only on that grant rather than on the earlier dealings, the premises and the rent records that may also matter. That can give the wrong result. Links between the deals, the premises and the rent records all matter.
- A new address does not always mean different premises.
- Separate documents can still form one arrangement.
- A later lease may change the SDLT position.
Key takeaways
- This HMRC page contains no calculation.
- Qualifying linked leases combine into one lease.
- Check the full lease history and documents.
Technical analysis
For advisers, and for anyone who wants to check the law behind this page. You do not need this section to understand the guidance above.
Legislation
- FA 2003 Schedule 17A para 5 — treating successive linked leases as one lease
- FA 2003 section 108 — when land transactions count as linked
- FA 2003 Schedule 5 para 2 — calculating stamp duty on lease rent
Official guidance
The pages below are HMRC’s guidance. Guidance is not law. It sets out how HMRC reads the legislation, and it is not binding on you, on a tribunal or on a court. Where guidance and the legislation differ, the legislation wins. HMRC can also change or withdraw guidance, and it may not cover your facts.
Where this is not settled
- The archived HMRC page does not explain the facts of any particular lease arrangement.
- Whether leases form part of one scheme, arrangement or series can depend on the documents and surrounding facts.
Evidence you would need
This kind of case is decided on the facts of the individual property. These are the records that usually settle it, and the ones an adviser would ask you for.
- Each lease and any agreement or side letter
- The premises covered by each lease
- Lease start dates, terms and rent schedules
- The parties to each lease and their connections
- The transaction effective dates
Explore this with an AI
Readers often want to test their own situation. Copy the prompt below into ChatGPT, Claude or Gemini. It hands the model the actual legislation for this page rather than letting it answer from memory, and tells it to be explicit about what is uncertain. What comes back is information, not advice – check it against the links above.
I am researching UK Stamp Duty Land Tax (SDLT), which applies in England and Northern Ireland. MY QUESTION SDLT on successive linked leases: why this HMRC page has no calculation [Replace this with your own situation: what you are buying, the price, the dates, who the buyer is, and what you plan to do with the property.] THE LAW THIS TURNS ON - FA 2003 Schedule 17A para 5 - treating successive linked leases as one lease https://www.legislation.gov.uk/ukpga/2003/14/schedule/17A/paragraph/5/2025-11-17 - FA 2003 section 108 - when land transactions count as linked https://www.legislation.gov.uk/ukpga/2003/14/section/108/2025-11-17 - FA 2003 Schedule 5 para 2 - calculating stamp duty on lease rent https://www.legislation.gov.uk/ukpga/2003/14/schedule/5/paragraph/2/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm19640 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. HMRC guidance is HMRC's view of the law, not the law, and does not bind a tribunal or a court. 2. Tell me what the rule actually requires, in plain English. 3. Tell me which facts decide the answer, and which facts would change it. 4. Tell me what evidence I would need to support the position. 5. Be explicit about anything unsettled or fact-sensitive. Do not guess. 6. Your training data has a cutoff and SDLT rates and reliefs change at fiscal events. Say so if you are not sure the law is current. POINTS ALREADY KNOWN TO BE UNCERTAIN ON THIS TOPIC - The archived HMRC page does not explain the facts of any particular lease arrangement. - Whether leases form part of one scheme, arrangement or series can depend on the documents and surrounding facts. Do not give me a conclusion you cannot support from the provisions above.
Legislation links show Finance Act 2003 as it stood on 2025-11-17. The law may have changed since, and the rules that apply are those in force on the date of your transaction. The official guidance this page is based on is here.
This page was last updated on 1 September 2026
Useful article? You may find it helpful to read the original guidance here: SDLT on successive linked leases: why this HMRC page has no calculation
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