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HMRC internal manual

Stamp Duty Land Tax Manual

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, under para 3(1)(b) 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, 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 (defined in para 3(4) 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