| Commentary

280 Reconstruction relief

| Commentary

280 Reconstruction relief

Under the provisions for reconstruction relief in Schedule 7 to the Finance Act 2003, a land transaction will be exempt from stamp duty land tax subject to certain conditions1. The rules and conditions are closely modelled on the stamp duty rules in Section 75 of the Finance Act 1986 although there are several significant differences2. Like the Section 75 relief, reconstruction relief in Schedule 7 to the 2003 Act will only apply to ‘across the board’ reconstructions, in other words, where all the shareholders in the transferring company end up owning the same

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