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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Group, reconstruction or acquisition relief

Group relief: No withdrawal: Examples

Vendor leaves the group

B Ltd is 100% owned by A Ltd. C Ltd is also 100% owned by A Ltd. These three companies form a group for the purposes of Stamp Duty Land Tax.

B Ltd (the vendor) transfers the freehold interest in a parcel of land to C Ltd (the purchaser) for no consideration. This is the relevant transaction. The market value of the freehold interest is £1,000,000. C Ltd claims group relief in respect of the transfer.

A Ltd then sells the shares in B Ltd to an unconnected third party within three years. The market value of the freehold interest is £1,750,000. As a result of the sale of shares B Ltd leaves the group on 07/07/06.

Group relief is not withdrawn. This is because the only reason the purchaser (C Ltd) has ceased to be a member of the same group as the vendor (B Ltd) is because the vendor has left the group.