SDLTM51010 - Procedure
Pre-transaction and post-transaction rulings under Code of Practice 10: Timing of request
Pre-transaction
It is to the benefit of both the Stamp Office and its customers
if requests for interpretation under COP10 are made in good time to
enable all necessary information to be supplied and considered.
This means that making applications in advance of the
transaction should be the preferred option for a taxpayer wishing
to seek the views of the Stamp Office.
Post-transaction, pre-return
The time between the effective date of a land transaction and
the date a land transaction return is required is short.
Although the Stamp Office will endeavour to provide a written
ruling before the return is due, this cannot be guaranteed where
the request is made after the transaction has taken place. It
follows that post-transaction, pre-return requests should be made
as soon as possible after the date of the transaction.
The Stamp Office does not expect that these requests will be
the norm.
Stamp duty land tax is a self-assessment tax and the
submission of a land transaction return should not be delayed
because a reply may not have been received in respect of a COP10
ruling request.
Post-transaction, post-return
Guidance cannot be given once a land transaction return has been
submitted.
Where correspondence or discussion is needed after a return
has been submitted the Stamp Office is likely to open a formal
enquiry into the return.
