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HMRC internal manual

Stamp Duty Land Tax Manual

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HM Revenue & Customs
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Reliefs: Group Tax Bulletin article: Subsales and group relief in stamp duty land tax

Paragraph 2(2) provides rules for stamp duty land tax (SDLT) based on those for stamp dutyin section 27(3) FA 1967. Section 27(3)(b) FA 1967 (intended to prevent acquisitions ofland from outside the group without stamp duty being paid) is not included in Schedule 7and this is because the problem it seeks to address, resting on contracts, is not relevantto SDLT. It is not possible to “rest on contract” to avoid SDLT because of thesubstantial’ performance rule in section 44 FA 2003 (seehttp://www.opsi.gov.uk/acts/acts2003/30014--e.htm#44) .