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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: Withdrawal: Events which may trigger withdrawal FA03/SCH7/PARA3

For withdrawal of the relief to be considered at the time the purchaser ceases to be amember of the same group as the vendor, the purchaser (or a relevant associated company)must hold

  • the chargeable interest that was acquired under the relevant transaction or
  • a chargeable interest derived from the chargeable interest acquired under the relevant transaction (for example, if a headlease was acquired under the relevant land transaction, the reversion of a sublease granted out of that headlease would be a chargeable interest derived from the original chargeable interest)

and

  • the chargeable interest has not subsequently been acquired at market value by means of a chargeable transaction where group relief was available but was not claimed.

For the purposes of withdrawal of the relief, a relevant associated company is acompany that

  • is a member of the same group as the purchaser immediately before the purchaser leaves the same group as the vendor
  • ceases to be a member of the same group as the vendor in consequence of the purchaser ceasing to be a member