Stamp duty—meaning of group
Stamp duty—meaning of group

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

  • Stamp duty—meaning of group
  • HMRC guidance—Stamp Taxes on Shares Manual
  • What a stamp duty group is
  • What entities can be members of a stamp duty group
  • Bodies corporate
  • Issued ordinary share capital
  • Tracing through certain tax transparent entities
  • Arrangements which break stamp duty grouping
  • Change of control arrangements
  • Degrouping arrangements
  • More...

Relief from stamp duty is available where beneficial ownership of stock or marketable securities is transferred between two bodies corporate that are members of the same stamp duty group provided that anti-avoidance provisions do not apply to bar relief. A successful claim to stamp duty relief in respect of an instrument of transfer relating to stock or marketable securities normally also cancels any charge to stamp duty reserve tax (SDRT) that arose on the agreement for that transfer (see Practice Note: Stamp duty reliefs—Procedure for claiming stamp duty relief and interaction with SDRT). For more information on stamp duty group relief, see Practice Note: Stamp duty reliefs—Intra-group relief and for a precedent letter applying for such relief, see Precedent: Application letter—stamp duty group relief—FA 1930, s 42.

This Practice Note explains what a stamp duty group is for the purpose of the relief from stamp duty for an intra-group transfer of stock or marketable securities. If the subject of the intra-group transfer is UK land, see Practice Notes:

  1. SDLT group relief and SDLT—meaning of group for land located in England

  2. Scotland: Land and buildings transaction tax (LBTT)—particular transactions and taxpayers—Group Relief for land located in Scotland, and

  3. Wales: Land transaction tax (LTT)—the basics for land located in Wales

Although this Practice Note refers to a 'stamp duty group', this term is not used in the legislation.

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