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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Group, reconstruction or acquisition relief

Reconstruction and acquisition relief: Withdrawal: Exceptions to withdrawal of reliefFA03/SCH7/PARA10

Reconstruction or acquisition relief is not withdrawn where control of the acquiringcompany changes as a result of

  • a share transaction effected in accordance with FA03/SCH3/PARA3. See SDLTM00550
  • a share transaction effected in accordance with FA03/SCH3/PARA4. See SDLTM00560
  • an exempt intra-group transfer. This is a transfer of shares effected by an instrument which is exempt from stamp duty by virtue of FA30/S42 or Section 11 of the Finance Act (Northern Ireland) 1954 and refers to transfers of shares between associated companies. Relief may be withdrawn following a subsequent non-exempt transfer. See SDLTM23250
  • a transfer of shares to another company in relation to which share acquisition relief applies. Relief may be withdrawn following a subsequent non-exempt transfer. See SDLTM23260
  • a loan creditor becoming, or ceasing to be, treated as having control of the company and no other change in control occurs