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Home Forums Patrick Cannon When are transactions linked for SDLT? Reply To: When are transactions linked for SDLT?

#360
Alastair Johnston
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At a course I attended last year, we were given an illustration of the linked transactions rules. We were told it had come from Crispin Taylor of HMRC – his hypothetical (I hope!) “Stamp Duty Chocolate Tax”. Relevant extracts:

(1) I go into a shop and buy 2 chocolate bars, each at the price marked on them. The transactions are not linked.

(2) The facts are as in (1) but the shopkeeper gives me a discount for bulk purchase. The transactions are linked.

(3) The facts are as in (1) but there are no prices marked. The shopkeeper takes a good look at me and names a price. The transactions are probably linked.

Unfortunately property purchases are in (3) above, as even if there is an asking price the buyer rarely ends up paying it exactly.