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Deconstructing Reconstructions

Cliona Murphy Tax Director Deloitte & Touche LLP discusses the impact of the introduction of SDLT on reconstructions and the effective creation of two separate stamp tax regimes
The most recent stamp duty reconstruction provisions are contained in Finance Act 1986 ss 75 and 76 in the form of a share-for-undertaking relief. With the introduction of Stamp Duty LandTax (SDLT) separate provisions were introduced in Finance Act 2003 Schedule 7 Part 2 paragraphs 7 and 8 replacing share-for-undertaking relief where the subject matter of the reconstruction is land. For land transactions s 75 relief has now been renamed 'reconstruction relief' and s 76 relief has acquired the title of 'acquisition relief'. As with the previous provisions acquisition relief is only a partial relief...
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