| Commentary

253.2 Stamp duty land tax

| Commentary

253.2 Stamp duty land tax1

A transaction is relieved from a charge to stamp duty land tax if the seller and purchaser are companies which on the effective date of the transaction are members of the same group2. For this purpose, companies are members of the same group if one is the 75% subsidiary of the other or they are both 75% subsidiaries of a third company3.

There are various restrictions on this relief, for example it will not be available if at the effective date of the transaction there are certain arrangements in existence by virtue of which, at that

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