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Section 77 stamp duty relief and company reorganisations

Speed read

The FA 2016 had an unpleasant surprise in the form of the introduction of an additional requirement for s 77 stamp duty relief on a share-for-share exchange. The amendment is intended to tackle stamp duty planning, but it also impacts genuine commercial transactions where there is no question of tax avoidance. In particular, one result of the amendment is to impose an extra cost where shareholders wish to partition a property company using the reduction of capital procedure – a transaction hitherto thought uncontroversial.

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