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SDLT Group Relief Clawback

Mike Dalton and Tony Hennessy both Tax Directors at Grant Thornton UK LLP explain recent changes to the SDLT group relief clawback rules
Although SDLT is a relatively young tax it has experienced considerable turbulence in the form of frequent amendments to the law largely related to anti-avoidance measures. One area which has been the subject of particular attention is the relief for land transactions between members of an SDLT group.
Group relief
Land transactions between members of a 'group' are in principle relieved from SDLT provided that the conditions in Finance Act 2003 Sch 7 para 1 are satisfied. Unlike a chargeable gains group a SDLT group...

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