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Stamp duty ― corporate transactions

Produced by Tolley in association with
Corporation Tax
Guidance

Stamp duty ― corporate transactions

Produced by Tolley in association with
Corporation Tax
Guidance
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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, the stamp duty legislation also includes important reliefs which apply in relation to particular corporate transactions.

The most commonly encountered reliefs are:

  1. associated company relief (known as group relief)

  2. relief for insertion of a new holding company

  3. reconstruction relief

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.

Reliefs should be applied for in writing with sufficient and appropriate evidence to support the claim.

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Sean Randall
Sean Randall

Partner at Blick Rothenberg , Corporate Tax


20 years’ “Big Four” stamp duty experience, including building and running KPMG’s UK stamp duty team for five years Chair of the professional body for stamp duty advisers, the Stamp Taxes Practitioners Group (over 200 members) Editor and author of Sergeant and Sims on Stamp Taxes since 2008 Former Tax Writer of the Year Author of the Law Society’s SDLT Handbook: A Guide for Residential Conveyancers Fellow of the Chartered Institute of Taxation Barrister (non-practising) Listed in Spear’s 500

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  • 14 Mar 2025 11:50

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