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Are SDLT Transactions 'Linked'?

Robin Mathew QC New Square Chambers considers when two or more land transactions are 'linked' and for SDLT anti-avoidance purposes treated as one
Stamp duty land tax (SDLT) is a new tax1 on land 'transactions' with a ponderous title and an awkward mnemonic which replaced stamp duty a dull difficult tax much avoided and 300 years old. Unlike stamp duty SDLT is not a tax on documents and their effect but on the transaction itself which procures a transfer of land or an interest in land.
As it is a progressive tax (and now a significant cost to many purchasers) it is essential in order to calculate the duty to define the chargeable 'transaction' and to ensure that...

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