I am assuming that by "links" you simply mean a
elements. If that's true then:
No. At least, not in the HTML5 draft specification:
If the a element has no href attribute, then the element represents a
placeholder for where a link might otherwise have been placed, if it
had been relevant.
From the HTML 4.01 specification:
Authors may also create an A element that specifies no anchors, i.e.,
that doesn't specify href, name, or id. Values for these attributes
may be set at a later time through scripts.