A contract is entered into on 1 August 2003 and substantially
performed on 1 September 2003.
On 1 November 2003 the contracting purchaser sub-sells.
The contract is completed by conveyance to the ultimate
purchaser on 1 January 2005.
There is no charge to Stamp Duty Land Tax on the contracting
purchaser because under the sub- sale rule in
SDLTM01060 completion by conveyance to
the ultimate purchaser does not trigger a charge on the contracting
purchaser.
