Policy paper

Stamp Duty Land Tax — group relief 

Published 28 October 2026

Who is likely to be affected 

Groups of companies holding English and Northern Irish property who transfer that property between group companies before disposing of it outside of the group. 

General description of the measure 

This measure makes changes to the Stamp Duty Land Tax (SDLT) group relief rules by introducing a change of control test to the winding-up exception for a company degrouping. 

The measure ensures that where a company claims group relief and then leaves the group within three years, the SDLT previously relieved is brought back into charge. 

Policy objective 

This measure ensures that the SDLT group relief rules apply as intended, so that groups of companies cannot use the winding-up exception to circumvent a SDLT charge arising on the transfer of property outside of the group. 

Background to the measure 

This measure was announced at Budget 2026. 

Detailed proposal 

Operative date 

This measure applies to land transactions with an effective date (usually the date of completion) on or after 29 October 2026.  

Current law  

The main SDLT legislation is contained in Part 4 of the Finance Act 2003, with the rules for group relief contained in section 62 and Part 1 of Schedule 7. 

Paragraph 1 of Schedule 7 exempts a land transaction from charge if the vendor and purchaser are group companies at the date of transaction (group relief). 

Paragraph 3 of Schedule 7 withdraws group relief if the purchaser and vendor cease to be members of the same group within the period of three years beginning with the effective date of transaction. 

Paragraph 4 of Schedule 7 provides that group relief is not withdrawn where the purchaser ceases to be a member of the same group as the vendor by reason of the winding-up of the vendor or any company that is above the vendor in the group structure. 

Proposed revisions 

Schedule 7 of the Finance Act 2003 will be amended so that the winding-up exception in paragraph 4(4) is moved into paragraph 4ZA and is subject to the change of control test in paragraph 4ZA. As a result, where the winding-up exception applies but is followed by a change of control of the purchaser in the three-year period following the effective date of transaction, group relief will be withdrawn. 

Summary of impacts 

Exchequer impact (£ million) 

2026 to 2027	2027 to 2028	2028 to 2029	2029 to 2030	2030 to 2031	2031 to 2032
Negligible	Negligible	Negligible	Negligible	Negligible	Negligible

This measure is expected to have a negligible impact on the Exchequer. 

Economic impact 

This measure is not expected to have any significant macroeconomic impacts. 

Impact on individuals, households and families 

This measure is expected to have no impact on individuals, households or families as it only affects businesses.  

Equalities impact 

This measure does not affect individuals, therefore it is not anticipated that there will be disproportionate impacts on any protected groups.  

Administrative impact on business including civil society organisations 

This measure is expected to have no impact on compliant businesses and civil society organisations. 

Operational impact (£ million) (HMRC or other) 

No operational impacts have been identified. 

Other impacts 

Other impacts have been considered and none have been identified. 

Monitoring and evaluation 

This measure will be monitored through information collected from SDLT returns and through regular communication with affected taxpayers and practitioners. 

Further advice 

If you have any questions about this change, contact the HMRC Stamp Taxes team at stamptaxes.budgetfinancebill@hmrc.gov.uk.