Linked Transactions: SDLT Rules for Connected Purchases
Linked transactions are two or more property deals between the same buyer and seller that HMRC treats as a single transaction for SDLT purposes. Aggregation usually increases the total tax bill, as it pushes more value into higher rate bands.
Last verified: April 2026 | Source: GOV.UK
Key Takeaways
- •SDLT is calculated on the total (aggregate) consideration of all linked transactions — not each one separately.
- •Transactions are linked if they are part of a single scheme, arrangement, or series between the same parties.
- •Connected persons (relatives, business partners, group companies) can cause transactions to be linked.
- •Each individual transaction still requires a separate SDLT return within 14 days of its effective date.
- •SDLT and LBTT/LTT transactions cannot be linked together across jurisdictions.
In this article
What Are Linked Transactions
HMRC treats two or more property transactions as "linked" when they are part of the same scheme, arrangement, or series — regardless of whether they are completed at the same time or covered by separate contracts.
The key question is whether the deals are commercially connected: would any one of them have happened without the others? If not, they are likely linked for SDLT purposes.
Single Arrangement
Transactions form part of a "single arrangement" when they are agreed together as part of one deal. Common examples include:
- •Buying two adjacent plots from the same seller, agreed in a single negotiation
- •Purchasing a main house and an associated garage under separate contracts but agreed simultaneously
- •Acquiring multiple flats in a block from the same developer under a package deal
Series of Transactions
Transactions can also be linked if they form a "series" — a sequence of deals that are connected even if not all agreed at the outset. HMRC looks at the overall commercial effect:
- •A developer buying land in phases from the same seller under a framework agreement
- •Multiple purchases from a seller as part of a structured portfolio acquisition
Connected Persons
Transactions can be linked even if different legal entities are involved, as long as those entities are "connected persons". Connected persons include:
- •Spouses and civil partners
- •Siblings, parents, grandparents, and their spouses
- •Business partners and their relatives
- •Companies under common control or in the same group
If a buyer and their connected person each buy a property from the same seller as part of the same deal, HMRC may treat both purchases as one linked transaction — aggregating the considerations for SDLT purposes.
How Tax Is Calculated on Linked Transactions
When transactions are linked, SDLT is calculated on the total aggregate consideration as if all the linked transactions were a single transaction. The tax on that total is then apportioned between the individual transactions in proportion to their respective consideration.
Example: Two properties purchased from the same seller
- Property A: £200,000
- Property B: £200,000
- Aggregate consideration: £400,000
- SDLT on £400,000 (standard residential):
- 0% on £125,000 = £0
- 2% on £125,000 = £2,500
- 5% on £150,000 = £7,500
- Total SDLT: £10,000
- vs £2,500 per property (£5,000 total) if assessed separately
Reporting Requirements
Even in linked transactions, each individual deal requires its own SDLT return filed within 14 days of that transaction's effective date. The total SDLT for all linked transactions is recalculated and the appropriate portion is declared on each return.
Where an earlier return has already been filed, it may need to be amended when subsequent linked transactions complete — as the aggregate consideration changes the rate that applied to the earlier transaction.
After MDR Abolition (June 2024)
Multiple Dwellings Relief (MDR) — which allowed buyers to calculate SDLT on the average price per dwelling rather than the total — was abolished from 1 June 2024. This means linked residential transactions now attract the full aggregated SDLT without any averaging relief.
For purchases of 6 or more residential properties in a single or linked transaction, non-residential rates may still apply and can result in a lower SDLT bill than residential rates on the aggregate amount.
Official Government Source
For official HMRC guidance on linked transactions:
SDLT: linked purchases or transfers — GOV.UKFrequently Asked Questions
What makes transactions linked for SDLT?
HMRC treats transactions as linked when there is more than one transaction between the same buyer and seller (or connected persons), and the transactions are part of a single scheme, arrangement, or series. It does not matter whether separate contracts are used — if the deals are commercially connected, they are likely linked.
Who counts as a connected person?
Connected persons include relatives (siblings, parents, grandparents, spouses, civil partners), business partners and their relatives, and companies within the same group. If a buyer's connected person is party to a related transaction, HMRC may treat both transactions as linked.
How does linking affect my SDLT bill?
When transactions are linked, SDLT is calculated on the total aggregate consideration of all linked transactions rather than each one individually. Since higher rates apply at higher price bands, aggregation usually results in more tax than if each transaction were assessed independently.
In this article
Emma Richardson, MRICS
Chartered Surveyor & Property Tax Specialist
Emma Richardson is a RICS-qualified Chartered Surveyor with over 12 years of experience in UK property taxation. She founded Calculate My Stamp Duty UK to help buyers understand the complex world of property transaction taxes.