SDLTM09110 - The notional transaction: Section 75A (4)

(This page was introduced on 15 January 2020)

Where the conditions for Section 75A to apply are all met:

• Any of the scheme transactions which are land transactions shall be disregarded, and
• in place of the scheme transactions that are land transactions, a notional land transaction is substituted comprising the disposal of V’s chargeable interest and an acquisition of that chargeable interest by P

On substituting with a notional land transaction, P will be treated as the purchaser who has acquired the chargeable interest that V has disposed of.

It will therefore be the responsibility of P to file the land transaction return in respect of the notional transaction and pay the SDLT due.

Any scheme transactions which are not land transactions will not be disregarded and should have been taken into account when calculating the chargeable consideration for the notional transaction, for further information see SDLTM09220.