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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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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).