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SDLTM09935 - SDLT - increased rates for non-resident transactions: Non-resident in relation to a chargeable transaction: Companies, second condition, examples You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals. (All legislative references are to Sch 9A FA03 unless otherwise stated) Example 1 Esther and Dahlia each own 50% of the share capital in Black Starling Ltd, a UK resident company for the purposes of Corporation Tax. It is not an excluded company under paragraph 11. On 1 February 2025, Black Starling Ltd purchases a freehold residential property in England for £465,000. To determine whether Black Starling Ltd is non-resident in relation to this transaction, we need to consider whether the second condition set out at paragraph 7(3) applies.

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