Policy paper

Stamp Duty Land Tax — changes to group relief

This measure is about changes to Stamp Duty Land Tax (SDLT) where group relief has been claimed on a purchase of land or property.

• From: HM Revenue & Customs
• Published: 28 October 2026

Documents

Stamp Duty Land Tax — group relief 

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Draft legislation

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Explanatory note

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Details

This measure introduces a change of control test for the winding-up exception in the SDLT group relief rules when a company degroups.

Group relief will be withdrawn and any additional SDLT charged if:

• a company claims group relief
• the winding-up exception later applies
• control of the purchasing company changes within 3 years of the group-relieved transaction

This measure applies to transactions with an effective date on or after 29 October 2026.