SDLTM00860 - Scope: What is chargeable

Contract and conveyance: General FA03/S44

In the vast majority of cases stamp duty land tax will arise on completion.

However a charge to stamp duty land tax will arise where a contract governing a land transaction is substantially performed before it is formally completed.

Whether or not a contract has been substantially performed is a question of fact.

SDLTM07700+ provides further guidance on the question of when substantial performance takes place.