Partial Freeport and Investment Zone stamp duty relief
Partial relief at a glance
Where qualifying land makes up at least 10% but less than 90% of the amount paid, the SDLT otherwise due is reduced by that percentage.
- Split the price on a just and reasonable basis.
- Check the land’s location and intended use.
- Keep evidence supporting the percentage used.
Scroll down for the full analysis.
Read the original guidance here:
Partial Freeport and Investment Zone stamp duty relief
If only some of the land you buy qualifies, you may reduce the stamp duty in part. Your central issue is how much of what you pay is attributable to qualifying land. Between 10% and less than 90%: the tax falls by that same percentage.
What this rule is about
Freeports and Investment Zones may contain special tax sites. Land in one of these sites can qualify for SDLT relief, but only where it also meets the separate legal tests. This article focuses narrowly but importantly on purchases combining qualifying and non-qualifying land.
Being inside a site, by itself, is insufficient. Intended use matters too. That difference can affect a substantial part of the stamp duty bill.
What the official source says
HMRC’s manual states that partial relief applies where qualifying land represents at least 10%, but less than 90%, of the amount paid for the whole purchase. You then reduce the tax by the qualifying percentage.
- Work out which land is qualifying land.
- Work out what share of the amount paid relates to it.
- Use a just and reasonable way to split that amount.
- Partial relief applies from 10% up to, but not including, 90%.
- Reduce the stamp duty otherwise due by that percentage.
What this means in practice
This is a reduction rather than a separate tax rate. Calculate the stamp duty due without relief first. Then reduce it by the qualifying share.
When areas have different values, you cannot simply use acreage alone. A smaller plot may contain a valuable building. Value can outweigh acreage.
- Keep a clear plan of the land bought.
- Identify the proposed use of each area.
- Check whether the contract gives separate prices for different parts.
- Support any split that does not follow the contract price.
How to analyse it
Start with the facts on completion day. Under the legislation, you must consider whether land lies in a special tax site and whether the buyer intends to use it only in a qualifying way.
- Is each area within the designated special tax site?
- What will each area be used for?
- Which areas meet the qualifying-land test?
- What is a fair share of the total price for those areas?
- Is that share at least 10% and below 90%?
- Apply that percentage to the tax due without relief.
Example
HMRC gives an example in which five acres are bought for £250,000 an acre, making a total price of £1.25 million, and all five acres lie in the special tax site. However, the buyer intends only four acres for a qualifying use. Where those four acres represent 80% of the price, the relief reduces the stamp duty otherwise due by 80%.
Why this can be difficult in practice
Splitting the price is usually the hard part. Instead of allowing a convenient split, the law requires one that is just and reasonable. A straightforward acreage calculation may be correct, but it may not be.
- Land inside the site may still fail to qualify because of its intended use.
- Different land uses can make a price split harder.
- A contract price allocation may need checking against the real value of each part.
- The HMRC manual explains HMRC’s view; the legislation remains the law.
Key takeaways
- Partial relief may apply where only part of a purchase is qualifying land.
- The qualifying share must be at least 10% and below 90%.
- The tax reduction matches the qualifying share of the price.
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 6C para 2 — when land counts as qualifying land
- FA 2003 Schedule 6C para 6 — when partial relief reduces the stamp duty charge
- FA 2003 Schedule 6C para 7 — how to fairly split the amount paid
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 source page does not explain the result where qualifying land represents less than 10% or at least 90% of the amount paid.
- What is just and reasonable will depend on the facts, including the land bought and its planned use.
- The supplied legislation is current only to 17 November 2025, so the position for a later transaction needs checking.
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.
- A plan showing which parts of the land are inside the special tax site
- The purchase contract and any price allocation
- Evidence of the intended use of each part of the land
- Valuation material supporting the proposed split
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 Partial Freeport and Investment Zone stamp duty relief [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 6C para 2 - when land counts as qualifying land https://www.legislation.gov.uk/ukpga/2003/14/schedule/6C/paragraph/2/2025-11-17 - FA 2003 Schedule 6C para 6 - when partial relief reduces the stamp duty charge https://www.legislation.gov.uk/ukpga/2003/14/schedule/6C/paragraph/6/2025-11-17 - FA 2003 Schedule 6C para 7 - how to fairly split the amount paid https://www.legislation.gov.uk/ukpga/2003/14/schedule/6C/paragraph/7/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm20285 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 source page does not explain the result where qualifying land represents less than 10% or at least 90% of the amount paid. - What is just and reasonable will depend on the facts, including the land bought and its planned use. - The supplied legislation is current only to 17 November 2025, so the position for a later transaction needs checking. 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: Partial Freeport and Investment Zone stamp duty relief
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