Application of exemptions and reliefs: Group Relief
There is a transfer of a chargeable interest from E Ltd to B Ltd.
The provisions of Sch15 would not have any application in this example as it is not a transfer from or to a partnership.
Therefore we look directly to the application of Sch7.
For group relief to apply for SDLT purposes the transfer must be between group companies and a company must be a body corporate and the 75% beneficial ownership test must be met.
As an EP/ELP is transparent under UK taxation laws B Ltd and C Ltd each own 50% of the issued share capital of E Ltd. As both B Ltd and C Ltd are 100% subsidiaries of A Ltd this is a group for SDLT purposes and if the requirements of Sch7/para2 are met group relief will apply to relieve any market value charge (FA03/S53).