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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Charities relief

Circumstances where relief is available where a charity or charitable trust holds the greater part of the land FA03/SCH8/PARA3

Where a charity or charitable trust is unable to claim relief on a land transaction

  • because it does not intend to hold the whole of the land for qualifying charitable purposes
  • but it does intend to hold the greater part for such purposes

then the whole of the transaction will be exempt from charge.

The greater part means 51% or more of the monetary value of the land; see the example 1 at SDLTM26030a.

If the charity disposes of part of that land or holds part of it for use for other than qualifying charitable purposes, a relevant portion of the relief will be clawed back. See the example 2 at SDLTM26030a.

This ensures that the relief granted is in proportion to the share of the land retained and held by the charity in furtherance of its charitable aims.