Situation 05
Linked transactions
Two or more transactions between the same parties may have to be looked at together. When they do, the rate, the base and sometimes the availability of relief all change.
The short answer
Linking is not optional and it is not always obvious. Transactions separated by months, structured as separate contracts, or involving different but connected parties can still fall to be treated as one.
Where this usually goes wrong
These are the patterns we see most often. Each one is a situation where the obvious answer and the correct answer are different.
Treating separate contracts as separate transactions
Separate paperwork does not by itself make transactions unlinked.
Connected parties on either side
Linking can arise through connection between sellers as well as between buyers.
A later transaction that changes an earlier one
A second acquisition can require the first return to be revisited.
Assuming linking is always bad
Sometimes it improves the position. Either way it has to be established rather than assumed.
Options, phasing and staged acquisitions
Deals structured in stages are the most common place this is missed.
The facts that decide it
If you want to know where you stand before you speak to anyone, these are the questions we will ask. Having the answers ready is most of the work.
- 01How many transactions are there, and between which parties?We map the whole set on paper before looking at any one of them in isolation.
- 02Are the parties connected, and how?Connection is established from ownership and relationships, on both sides of each deal.
- 03What are the effective dates of each?The sequence is taken from the completion documents for every transaction, not from memory.
- 04Do the transactions form part of a single arrangement or scheme?How the deals were negotiated and documented is what answers this.
- 05What is the total consideration across all of them?Everything given across the set has to be identified, not only the headline prices.
- 06Have returns been filed on any of them, and on what basis?What has already gone in shapes what can now be done and in which order.
- 07Are any of them conditional on the others?Conditionality is read from the contracts rather than from how the deal was described.
- 08Is any part of the property non-residential?What is being acquired has to be established from the titles before anything else.
What we would want to see
The analysis is only as good as the documents behind it. For this situation, that normally means:
- Contracts for every transaction in the arrangement
- Title registers and title plans for each property
- Completion statement, where available
- Details of every property interest held
- Evidence of any disposal and its date
- Details of all purchasers and their positions
- Any existing SDLT return and UTRN
- Correspondence with the conveyancer on the point
Questions we get on this
The purchases were months apart. Can they still be linked?
That is possible. Separation in time does not settle it on its own. What we look at is who the parties are, how they are connected and whether the transactions form part of a single arrangement.
We bought two flats in the same block from the same seller. Does that matter?
It is exactly the pattern we would want to look at. Two acquisitions from the same seller are examined together before any conclusion is reached about either of them.
A return has already gone in on the first purchase. What now?
Then the question is what the correct position was across all of the transactions and, separately, what can now be done about any difference. We establish the first before considering the second.
Will you just tell me what I want to hear?
No. Our fee is fixed and does not depend on the outcome, which means we have no interest in finding a saving that is not there. If the original return was right, we will tell you that in writing, and you will have a reasoned position on file if it is ever looked at.
This page is general information only and is not advice. It applies to transactions in England and Northern Ireland. Reviewed 16 August 2026.