My client has a trading business and is renewing their lease after it expired. He is also expanding the trading premises by leasing the unit next door from the same landlord; he is paying monthly rent on the 10-year leases rather than a premium. Having calculated the net present value (NPV) of the rents, should they be taxed separately for stamp duty land tax (SDLT) purposes or combined?

It seems that these may be ‘linked leases’ in which case a combined figure of net present value would be required for SDLT purposes.

Section 108 Finance Act 2003 (FA 2003) defines linked transactions for SDLT purposes as ‘part of a single scheme, arrangement or series of transactions between the same vendor and purchaser or, in either case, persons connected with them’.

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