On 12 October, HMRC announced that, contrary to its previously held view, it will now regard an LLP as a 'body corporate' for the purposes of both SDLT and stamp duty group relief. According to HMRC, the main consequence of this change is that an LLP can now be the parent in a group structure. On the face of it, this would appear to be good news, but as ever, the devil is in the detail and it would appear from a careful reading of the revised guidance that, overall, taxpayers may in fact be in a worse position.
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