Grant of a reversionary lease: this HMRC page gives no SDLT rule
What this source tells you
The supplied HMRC page is archived and does not explain stamp duty on a reversionary lease.
- It only notes Scotland’s move from SDLT in April 2015.
- It gives no lease rule or calculation.
- Do not rely on its title alone.
Scroll down for the full analysis.
Read the original guidance here:
Grant of a reversionary lease: this HMRC page gives no SDLT rule
Grant of a reversionary lease: this HMRC page gives no SDLT rule
This HMRC page does not explain how stamp duty applies to a reversionary lease. The supplied content consists only of an archive notice about Scotland. That matters: you cannot safely calculate a tax bill from this page.
What this rule is about
Parties usually arrange a reversionary lease so that it begins after an existing lease ends. The page title suggests that topic. Yet the supplied text sets out no rule for it.
What the official source says
HMRC’s archived notice makes one point only: from April 2015, SDLT no longer applied to land transactions in Scotland. It says Scottish transactions would instead fall under Land and Buildings Transaction Tax.
- The notice is marked as archived.
- It refers to Scotland.
- It gives no rule on a reversionary lease.
- It gives no tax rate or threshold.
What this means in practice
Do not treat this page as confirmation that no stamp duty is due, or that it is due. Its title alone is insufficient. The lease documents and the property location are likely to matter.
- Check whether the property is in England or Northern Ireland.
- Check whether it is in Scotland.
- Keep the existing and proposed lease documents together.
- Record every payment connected with the grant.
How to analyse it
Begin with the underlying facts rather than the paperwork’s label. Then identify the legislation in force when parties granted the lease, where the property stands, and whether the new term overlaps an earlier lease. Check those points first.
- Is there an earlier lease?
- When does the new lease start?
- Does it overlap with the earlier lease?
- What rent, premium or other payment is due?
Example
Sam signs a lease now, but it starts when another tenant’s lease ends. People may call this a reversionary lease. Because it sets no rule for that situation, the archived notice cannot answer Sam’s stamp-duty question.
Why this can be difficult in practice
An HMRC page title can lead people to think it supplies the answer. Here, it does not. Moreover, the archive note addresses Scotland; SDLT is the land tax for England and Northern Ireland.
- A page title is not a tax calculation.
- An archive notice is not a full legal explanation.
- Scottish rules should not be assumed to apply elsewhere.
Key takeaways
- This source has no reversionary-lease rule.
- It only gives an archived Scotland notice.
- More facts and the relevant legislation are needed.
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.
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 page gives no facts, rule or calculation for a reversionary lease.
- The correct SDLT treatment cannot be determined from this source alone.
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.
- The lease and any earlier lease it follows
- The grant date, start date and length of each lease
- Details of any premium, rent or other payment
- The location of the property
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 Grant of a reversionary lease: this HMRC page gives no SDLT rule [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.] HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm19672 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 page gives no facts, rule or calculation for a reversionary lease. - The correct SDLT treatment cannot be determined from this source alone. 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: Grant of a reversionary lease: this HMRC page gives no SDLT rule
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