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Policy paper

Draft legislation (accessible version)

Published 28 October 2026

© Crown copyright 2026

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This publication is available at https://www.gov.uk/government/publications/stamp-duty-land-tax-changes-to-group-relief/draft-legislation-accessible-version

1 Withdrawal of group relief

  1. (1) Part 1 of Schedule 7 to FA 2003 (stamp duty land tax: group relief) is amended as follows.

  2. (2) In paragraph 4 (cases in which group relief not withdrawn), omit sub paragraphs (4) and (5).

  3. (3) In the italic heading before paragraph 4ZA, after “vendor” insert “is wound up etc or”.

  4. (4) In paragraph 4ZA (group relief not withdrawn where vendor leaves group)—

    1. (a) in sub-paragraph (1)—

      1. (i) after “vendor”, in the first place it occurs, insert “—

        1. (a) by reason of anything done for the purposes of, or in the course of, winding up the vendor or another company that is above the vendor in the group structure, or”;

      2. (ii) the remaining text becomes paragraph (b);

    2. (b) in sub-paragraph (2), for “The vendor is” substitute “For the purpose of sub-paragraph (1)(b) the vendor is”;

    3. (c) in sub-paragraph (3), for “purpose of sub-paragraph (2)” substitute “purposes of sub-paragraphs (1) and (2)”;

    4. (d) in sub-paragraph (4), for “vendor leaves the group” substitute “purchaser ceases to be a member of the same group as the vendor (as mentioned in sub-paragraph (1))”.

  5. (5) The amendments made by this section have effect in relation to land transactions the effective date of which falls on or after 29 October 2026.

  6. (6) But those amendments do not have effect in relation to a land transaction which—

    1. (a) is effected in pursuance of a contract entered into before 29 October 2026, and

    2. (b) is not excluded.

  7. (7) For this purpose a land transaction is excluded if—

    1. (a) there is any variation of the contract, or assignment of rights under the contract, on or after 29 October 2026,

    2. (b) the transaction is effected in consequence of the exercise on or after that date of any option, right of pre-emption or similar right, or

    3. (c) on or after that date, there is an assignment, subsale or other transaction relating to the whole or part of the subject-matter of the contract as a result of which a person other than the purchaser under the contract becomes entitled to call for a conveyance.

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