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HMRC internal manual

Stamp Taxes on Shares Manual

Exemptions and reliefs: reliefs: stamp duty group relief - bodies corporate

Bodies Corporate

The term ‘body corporate’ is not restricted to companies. ‘Body corporate’ includes companies with limited or unlimited liability, companies limited by guarantee, charter companies and bodies created by statute. Relief may be available where a local authority, being a body corporate, is a party to a document and the other party has a share capital which is beneficially owned by the authority. See STSM042260 regarding foreign entities.

Body corporate with no share capital

A body corporate which has no share capital can only be associated with another body corporate if it is that body’s parent.