Stamp duty on linked leases: when separate leases count as one
Linked leases in brief
Successive leases can be combined for SDLT where they are linked and concern the same, or substantially the same, premises.
- The combined term is used.
- Rent under all linked leases is included.
- The supplied HMRC page is archived rather than a calculation guide.
Scroll down for the full analysis.
Read the original guidance here:
Stamp duty on linked leases: when separate leases count as one
Stamp duty on linked leases: when separate leases count as one
For stamp duty, separate leases can sometimes count as one. When the leases are linked and cover the same, or much the same, premises, you may need to calculate using their combined term and rent.
What this rule is about
When a planned renewal, extension, or replacement arrangement leads a tenant to take another lease of the same space, separate documents do not necessarily keep the leases separate for SDLT. Labels do not decide the outcome.
The law can combine the leases into one longer lease. It considers the rent across the whole series together.
What the official source says
HMRC has archived the supplied page. The page says only that Scotland moved from SDLT to Land and Buildings Transaction Tax from April 2015, and it offers no working calculation. The legislation provides the rule for England and Northern Ireland.
- The leases must be successive.
- They must cover the same or substantially the same premises.
- The grants must be linked transactions.
- A linked transaction forms part of one scheme, arrangement, or series.
What this means in practice
Where the test is met and the leases form a linked successive series over the same, or substantially the same, premises, calculate SDLT as for one lease. Count from the first lease grant. Its length is the total of all the lease terms.
- Add the terms of the leases together.
- Include rent payable under every lease in the series.
- Do not assess each later lease in isolation.
How to analyse it
Start with the documents, not the labels. Ask whether the leases were really parts of one planned arrangement.
- List every lease in date order.
- Compare the plans and the areas let.
- Check whether the premises are substantially the same.
- Read side agreements, options, and renewal terms.
- Identify connections between the parties.
- Combine the terms and rent if the test is met.
Example
Ravi takes a three-year lease of a unit at £10,000 a year. An agreed two-year replacement lease then follows at £12,000 a year. If the leases are linked, concern substantially the same unit, and form part of the agreed replacement arrangement, the law treats them as one five-year lease. The rent considered across the series is £54,000: £30,000 plus £24,000.
Why this can be difficult in practice
The facts often make this difficult. When a changed plan is minor, the later lease may still cover substantially the same premises, but a greater change may mean that it covers different premises. Check the plans carefully. An informal commercial understanding may also show one arrangement, even without one signed master agreement.
- A new lease is not automatically a separate SDLT event.
- Different rent does not, by itself, break the link.
- Similar premises are not always substantially the same premises.
- Keep the papers that explain why the leases were granted.
Key takeaways
- Linked successive leases may count as one lease.
- The combined term and all rent are relevant.
- Check the arrangement and the premises carefully.
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 section 108 — when transactions form one linked arrangement
- FA 2003 Schedule 17A para 5 — treating linked successive leases as one lease
- FA 2003 section 48 — land interests within the SDLT regime
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
- Whether leases are substantially for the same premises, or are part of one arrangement, depends on the documents and surrounding facts.
- The supplied statutory material is current only to 17 November 2025. Current-law verification is needed for a transaction after that date.
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.
- Every lease and any agreement for renewal or replacement
- Plans showing the premises covered by each lease
- Dates, terms and rent schedules for all leases
- Evidence of the parties and any connected-person relationship
- Correspondence showing whether the leases formed one arrangement
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 Stamp duty on linked leases: when separate leases count as one [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 section 108 - when transactions form one linked arrangement https://www.legislation.gov.uk/ukpga/2003/14/section/108/2025-11-17 - FA 2003 Schedule 17A para 5 - treating linked successive leases as one lease https://www.legislation.gov.uk/ukpga/2003/14/schedule/17A/paragraph/5/2025-11-17 - FA 2003 section 48 - land interests within the SDLT regime https://www.legislation.gov.uk/ukpga/2003/14/section/48/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm19650 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 - Whether leases are substantially for the same premises, or are part of one arrangement, depends on the documents and surrounding facts. - The supplied statutory material is current only to 17 November 2025. Current-law verification is needed for a transaction after that date. 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: Stamp duty on linked leases: when separate leases count as one
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