Philip Simpson, K.C., successfully acted for the taxpayer in Archer (UK) Limited v. Revenue Scotland. The case concerned transitional provisions relating to the replacement of stamp duty land tax in Scotland by land and buildings transaction tax in the context of leases. Archer was the tenant under a lease entered into when SDLT still applied. The term of the lease was extended by variation after LBTT had replaced SDLT. In Scots law (in contrast with English law), it is possible to extend the term of a lease in this way without being deemed to have surrendered the lease and entered a new one in its place. The First-tier Tribunal held that the transitional provisions did not apply in this scenario so as to mean there was a new, deemed lease. The consequence is that the extension of the term did not count as a land transaction, and no LBTT was due.