SDLT on linked transactions shared ownership

xnoxxnox

Assuming property value in 570 000 and it's market value does not change, and it is a shared ownership, thus one is "stair-casing". All purchased in 2015.

What amounts of SDLT are payable at which stages?
Case1:
Purchase 25%, purchase 55% (thus not over 80%), purchase 20%.

Case2:
Purchase 25%, purchase 75%.

The values of possible transaction rations are:
20% - 114000
25% - 142500
55% - 313500
75% - 427500

I'm calculating Case1 as:
350 - 0 - 0

I'm calculating Case2 as:
350 - 11375

What I am confused about is whether or not the transactions count as linked thosed that are: after first AND which do not take one over 80% of ownership?

I.e. is there an "additional" SDLT payable on the 2nd transaction in Case 1 or not?

xnoxxnox

A reference to legislation would be good, as i cannot find any sources as to where the 80% threshold comes from which gov.uk "guides" simply mentioned out of the blue. If it was wikipedia, i'd totally mark that claim with [citation needed].

xnoxxnox

http://www.hmrc.gov.uk/manuals/sdltmanual/SDLTM27060.htm

I believe the calculated cases are done correctly.

The link above is for staircasing original grant and it states:
"any such acquisition is exempt from charge if, immediately afterwards, the total share of the dwelling held by the lessee or lessees does not exceed 80%"

xnoxxnox

http://www.hmrc.gov.uk/manuals/sdltmanual/SDLTM27065.htm

Oh and retrospectively transactions do not become chargeable from now on.

libf

Are you sure you're allowed to staircase that many times in a year? Doing so implies you could afford to buy on the open market...