Application of basic rules and introduction to corporate reliefs

The basic rules for stamp duty apply to companies as they do to other taxpayers. See the Stamp duty - basic rules guidance note for an introduction to the stamp duty regime.

However, stamp duty legislation also includes important reliefs which apply in relation to particular corporate transactions.

The most commonly encountered reliefs are:

  • associated company relief (known as group relief) (FA 1930, s 42 (subscription sensitive))
  • relief for insertion of a new holding company (FA 1986, s 77 (subscription sensitive))
  • reconstruction relief (FA 1986, s 75 (subscription sensitive))

These are explained in further detail below.

There are also reliefs applicable for transfers to recognised intermediaries, repurchases and stock lending, and transfers to charities.

In contrast to transactions which are exempt from stamp duty, even where reliefs eliminate the stamp duty liability in full, the transfer document will still need to be sent to HMRC for adjudication and stamping. See the Stamp duty - basic rules guidance note for further details.

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