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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Charities relief - Non Charity Purchasers

Partial Relief is available where a charity acquires jointly with a non charity or where a non charity acquires for charitable purposes FA03/SCH8/PARA3A-3C

Where a qualifying charity acquires as tenant in common with one or more non qualifying charities and none of the purchasers enters into the transaction with a tax avoidance purpose, then provided tahe charity intends to hold its undivided share of the subject-matter of the transaction for qualifying charitable purposes, relief is available for the lower of the proportion of the subject matter held by or the chargeable consideration provided by the qualifying charity or charities.


Relief - or an appropriate proportion of relief - under FA03/SCH8/PARA3A is withdrawn if the charity ceases to be established for charitable purposes only for if the chargeable interest - or any derived interest - ceases to be used to be used for qualifying charitable purposes.


Relief will still be available where a charity is not a qualifying charity but it intends to hold the greater part of its interest for qualifying charitable purposes.