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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Demutualisation of insurance company

Detailed rules: Qualifying transfer

Relief from Stamp Duty Land Tax may be claimed on a transaction entered into for the purposes of, or in connection with, a qualifying transfer of part or the whole of the business of a mutual insurance company to a company that has share capital (the acquiringcompany).

A qualifying transfer is one that is the transfer of business

  • consisting of the effecting or carrying out of contracts of insurance and takes place under an insurance business transfer scheme
  • of a general insurance company carried on through a permanent establishment in the United Kingdom and takes place in accordance with authorisation granted outside the United Kingdom for the purposes of

    • Article 14 of the life assurance Directive or
    • Article 12 of the 3rd non-life assurance Directive

and where the requirements in SDLTM23520 are met inrelation to the shares of a company (the issuing company) which is either the acquiring company or of which the acquiring company is a wholly owned subsidiary.