Stamp taxes and groups
In this lesson, you'll learn how stamp duty land tax works when property transfers between group companies, and crucially, what happens when that exemption is withdrawn.
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In this lesson
- 0:00 Stamp duty exemption for group transfers
- 0:37 When the exemption is withdrawn
- 1:26 Worked example: Epitome Limited scenario
- 2:48 Calculating clawback duty on group exit
- 3:51 Key principle: retrospective valuation method
About this lesson
We cover the 75% group relief that makes intra-group property transfers exempt from stamp duty land tax, the three-year clawback rule that applies if the recipient company leaves the group whilst still holding the asset, and how to calculate the tax charge that becomes due. This is essential exam knowledge for TX and ATX questions, where group structure changes often feature alongside property transactions. The core principle is straightforward: transfers of property between members of a 75% group are exempt from stamp duty land tax, but only if the recipient stays in the group. If that company leaves the group within three years of receiving the property and still owns it, the exemption is withdrawn and stamp duty land tax becomes payable. The amount charged is calculated by going back to the original transfer date and working out what the tax would have been if the exemption had never applied. We walk through a worked example involving a parent company with two subsidiaries where property moves between them, then one subsidiary is sold outside the group, triggering a stamp duty land tax charge. This is a common exam scenario worth knowing inside out.
Duration: 4m
Transcript
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