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HMRC internal manual

Stamp Duty Land Tax Manual

From
HM Revenue & Customs
Updated
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Reliefs: Group, reconstruction or acquisition relief

Group relief: General overview FA03/SCH7/PART1

This schedule provides for relief from stamp duty land tax where land and buildings aretransferred within a group of companies (or bodies corporate), where certain conditionsare met. See SDLTM23020+.

This relief allows groups to move property for commercial reasons without having toconsider stamp duty land tax implications.

If the purchaser and vendor of a chargeable interest are companies and, at the effectivedate of the land transaction, they are both members of the same group, relief from stampduty land tax may be claimed by the purchaser.

This is so that stamp duty land tax is not paid on property transfers within groups. Thepurchasing company may choose to pay the tax by not claiming the relief.

There are certain restrictions on availability. See SDLTM23030+

Where group relief from stamp duty land tax has been claimed on a land transaction (therelevant transaction) any subsequent withdrawal of the relief must be reported by thepurchaser on a new land transaction return. See SDLTM50400.

A new land transaction return should also be submitted if the purchaser ceases to be amember of the same group as the vendor

  • before the end of a period of three years beginning with the effective date of the relevant land transaction
  • in pursuance of, or in connection with, arrangements made before the end of a period of three years beginning with the effective date of the relevant land transaction