Guidance on Completing SDLT1 Form for Linked Property Transactions

Reporting Linked Transactions on an SDLT Return

Linked transactions are not taxed separately for SDLT rate purposes. If transactions are linked, question 13 on SDLT1 must show the total consideration for all linked transactions, including VAT, even where separate returns are needed. A single SDLT1 can only be used in limited cases where the linked transactions match on code, effective date, parties and relief position.

• Transactions are generally linked if they form part of a single scheme, arrangement or series between the same buyer and seller, or connected persons.
• If transactions are linked, the total linked consideration is used to determine the SDLT rate, but each return may still show tax only for the individual transaction.
• One SDLT1 return is only allowed if all linked transactions have the same transaction code, the same effective date, identical buyers and sellers, and either no relief or the same relief.
• If those conditions are not all met, a separate SDLT1 must be filed for each transaction, with question 13 still showing the total amount paid for all linked transactions other than rent.
• Where one overall price covers several linked transactions, it must be split on a just and reasonable basis, and the buyer should keep evidence of how that apportionment was worked out.

Scroll down for the full analysis.

How to report linked transactions on an SDLT return

This page explains how linked transactions should be shown on an SDLT return, especially question 13 on form SDLT1. The issue matters because linked transactions are not looked at in isolation for SDLT purposes. If transactions are linked, the total consideration across all of them affects the rate of tax, even though each transaction may still need its own return or tax figure.

What this rule is about

SDLT treats some transactions as connected to each other. These are called linked transactions. Broadly, transactions are linked if they form part of a single scheme, arrangement or series of transactions between the same buyer and seller, or persons connected with them.

The practical effect is important. When transactions are linked, the total amount paid across all of them must be taken into account. That total is entered in question 13 of SDLT1. It is used to determine the SDLT rate that applies.

This guidance is about how to complete the return correctly once you have decided that transactions are linked. It is not the full legal test for whether transactions are linked, but it assumes that question has already been considered.

What the official source says

The official material says you must answer the linked transactions question. If the transaction is linked to any others, you answer yes and enter the total amount paid for all linked transactions, including any VAT. If the transaction is not linked, you answer no and leave the rest of that question blank.

It then sets out two ways to notify linked transactions:

• one SDLT1 return with supplementary forms, but only if strict conditions are met
• a separate SDLT1 for each transaction, which is required if those conditions are not met

A single SDLT1 can only be used where all linked transactions:

• fall within the same transaction code at question 2, being all A, all F, all L or all O
• have the same effective date
• have identical purchasers and identical vendors
• either claim no reliefs at all, or all claim the same relief

If those conditions are not all satisfied, separate SDLT1 forms must be used.

Where separate SDLT1 forms are used, each return shows the consideration for that transaction only, but question 13 must still show the total consideration other than rent for all linked transactions. The tax on each return is then calculated by applying the SDLT rate appropriate to that total linked amount, but only to the consideration for the individual transaction shown on that return.

The guidance also deals with apportionment. If one overall price was agreed for all linked transactions, that price should be divided between the transactions on a just and reasonable basis. The purchaser does not need a professional valuation for this, but should keep evidence showing how the apportionment was worked out.

What this means in practice

The key point is that linked transactions can change the SDLT outcome even when there are several separate contracts or transfers. You do not simply calculate tax on each transaction in isolation.

There are really two separate questions:

1. Are the transactions linked?
2. If they are, can they be reported on one SDLT1, or must they be reported on separate SDLT1 forms?

If transactions are linked, question 13 becomes central. It asks for the total paid for all linked transactions. That total affects the SDLT rate banding.

But linked transactions do not always go on one return. A single return is only an administrative option available in a narrow set of cases. If the linked transactions differ in code, effective date, parties, or relief position, separate returns are required.

This distinction matters because people sometimes assume that “linked” means “one return”. That is not correct. Transactions can be linked for SDLT purposes but still need separate SDLT1 forms.

The guidance also shows that connected persons can matter when deciding whether the parties are effectively the same for linked transaction purposes. The source refers to the connected persons rules in section 1122 of the Corporation Tax Act 2010.

How to analyse it

A sensible way to approach the issue is as follows.

1. Decide whether the transactions are linked

Ask whether they form part of a single scheme, arrangement or series of transactions between the same buyer and seller, or connected persons. If yes, the linked transactions rules may apply.

2. Identify the transaction code for each transaction

The guidance distinguishes between codes A, F, L and O. A single SDLT1 is only possible if every linked transaction falls within the same code.

3. Check whether the effective dates match

If the linked transactions do not all have the same effective date, you cannot use one SDLT1 for all of them. Separate SDLT1 forms must be used.

4. Check whether the parties are identical

The single-return method requires identical purchasers and identical vendors across all linked transactions. If the parties differ, even because connected persons are involved, separate returns are required.

5. Check the relief position

If one transaction claims a relief and another does not, or if different relief codes apply, separate returns must be used. A single SDLT1 is only available if no relief is claimed for any of them, or all claim the same relief.

6. Work out the total linked consideration

If the transactions are linked, question 13 should include the total amount paid for all linked transactions, including VAT. In lease cases under code L, the guidance distinguishes between premium and rent and says that where there is no premium, 0 should be entered.

7. If there is one overall price, apportion it

If one combined price was negotiated for all the linked transactions, divide that price between the individual transactions on a just and reasonable basis. The guidance says the purchaser may estimate this apportionment and does not need a professional valuation, but should keep supporting evidence.

8. Calculate the tax correctly

Where separate returns are required, each return should show only that transaction’s own consideration, but the SDLT rate used should be the rate appropriate to the total linked amount shown in question 13. The tax entered at question 14 is only the tax payable for that individual transaction.

Example

This is an illustration of how the reporting works.

A buyer acquires two properties from the same seller as part of one overall arrangement. The transactions are linked. The two purchases have the same effective date, the same buyer and seller, and no relief is claimed. If they also fall within the same SDLT code, they may be notified on a single SDLT1 with the appropriate supplementary forms. In that case, the return shows the total consideration for both transactions in the relevant boxes, the total tax for both transactions, and the total number of properties.

Now change one fact. Suppose the two linked transactions have different effective dates. They are still linked, so question 13 on each return must reflect the total linked consideration. But they can no longer be reported on one SDLT1. Separate SDLT1 forms are required.

If one combined price was agreed for both properties, that combined price must be apportioned between them on a just and reasonable basis before completing the separate returns.

Why this can be difficult in practice

The hardest issue is often not form-filling but deciding whether transactions are linked in the first place. The test refers to a single scheme, arrangement or series of transactions, which can be fact-sensitive.

Another difficulty is separating the legal effect of linkage from the administrative method of filing. A transaction may be linked for tax purposes even though it cannot be included on the same SDLT1 as the others.

Apportionment can also be awkward where a package price was agreed. The guidance allows the purchaser to make their own just and reasonable estimate, but that does not remove the need for a sensible basis. If HMRC later opens an enquiry, the buyer may need to explain why the apportionment was reasonable.

Lease cases can be especially technical because the form distinguishes between premium and rent, and the boxes to be completed differ depending on the transaction code.

Key takeaways

• If transactions are linked, question 13 must show the total consideration for all linked transactions, including VAT.
• Linked transactions do not always go on one SDLT1; separate returns are required unless strict conditions for a single return are met.
• If one overall price covers several linked transactions, it must be apportioned on a just and reasonable basis, and evidence of that apportionment should be kept.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Guidance on Completing SDLT1 Form for Linked Property Transactions

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