SDLT—meaning of group
SDLT—meaning of group

The following Tax practice note provides comprehensive and up to date legal information covering:

  • SDLT—meaning of group
  • What an SDLT group is
  • What entities can be members of an SDLT group
  • Bodies corporate
  • Issued ordinary share capital
  • Tracing through certain tax transparent entities
  • Arrangements which break SDLT grouping
  • Change of control arrangements
  • Degrouping arrangements
  • Key points
  • More...

SDLT—meaning of group

An exemption from stamp duty land tax (SDLT) can be claimed where an interest in land is acquired (a land transaction) by one body corporate (referred to as the purchaser in the legislation) from another body corporate (referred to as the vendor in the legislation) provided that, at the effective date of the land transaction:

  1. both bodies corporate are members of the same SDLT group, and

  2. the anti-avoidance provisions do not apply to bar relief

See Practice Note: SDLT group relief for more information.

Even if a transaction legitimately qualifies for relief, certain post-transaction events can result in all, or a proportionate part of, the relief being clawed back. See Practice Note: Clawback of SDLT group relief for more detail.

SDLT ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that date, land and buildings transaction tax (LBTT) applies to such transactions, subject to transitional provisions. Consequently, references in this Practice Note to 'UK land' or similar expressions in the context of the application of SDLT should be read to exclude any interests in or over land in Scotland from 1 April 2015. For further details, see the LBTT subtopic.

SDLT ceased to apply to any land transaction involving any interest in or over land in Wales from 1 April 2018. From that date,

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