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Are SDLT Transactions 'Linked'?

Robin Mathew QC, New Square Chambers, considers when two or more land transactions are 'linked' and, for SDLT anti-avoidance purposes, treated as one

 
Robin Mathew QC New Square Chambers considers when two or more land transactions are 'linked' and for SDLT anti-avoidance purposes treated as one
 
Stamp duty land tax (SDLT) is a new tax1 on land 'transactions' with a ponderous title and an awkward mnemonic which replaced stamp duty a dull difficult tax much avoided and 300 years old. Unlike stamp duty SDLT is not a tax on documents and their effect but on the transaction itself which procures a transfer of land or an interest in land.
 
As it is a progressive tax (and now a significant cost to...

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