FA03/S45(5) and FA03/S45Adeal with the case where the transfer
of rights relates to part only of the subject matter of the
original contract.
Where part of the subject matter of the contract is retained
by the purchaser and part transferred to a sub-purchaser, providing
that the original contract has not been substantially performed,
then Stamp Duty Land Tax is calculated with reference to the
appropriate apportioned consideration for each.
The transaction is then treated as if there were two separate
contracts between the vendor and the purchaser, and the vendor and
the sub-purchaser.
The appropriate rate of tax is calculated with reference to
the consideration for each.
Examples of transfers of part can be seen at
SDLTM01110a.
