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HMRC internal manual

Stamp Taxes on Shares Manual

From
HM Revenue & Customs
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Exemptions and reliefs: reliefs: stamp duty group relief - company purchase of own shares

A purchase by a company of its own shares from one of its associated companies can qualify for relief. Where a 100% subsidiary company purchases some of its own shares from its parent under section 162 of the Companies Act 1985 or Article 47 of the Companies (Northern Ireland) Order 1982, (and FA86/S66 therefore applies), relief may be available under section 42. This is provided that the conditions are satisfied, in particular that the purchase of the shares was not part of an arrangement under FA67/S27(3).