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HMRC internal manual

Stamp Taxes on Shares Manual

Exemptions and reliefs: reliefs: company reconstructions and acquisitions - 'bona fide commercial reasons' and 'tax avoidance'

A condition for relief under section 75 or 77 depends on the acquisition being effected for bona fide commercial reasons and not for the purpose of tax avoidance. HMRC accepts that this condition is satisfied if the customer has obtained advance clearance for the scheme under TCGA92/S138, TCGA/S139(5), ITA07/S701 or CTA10/S748 - see - provided that copies of the application and clearance correspondence are supplied and the details given therein accurately reflect the events which actually took place.

Relief under section 77 may not apply in certain circumstances (see STSM042460).