SDLTM23081 | Reliefs: Group, reconstruction or acquisition relief

This provision applies to all group relief claims for transactions with an effective date on or after 13 March 2008.

The vendor is regarded as leaving the group where the purchaser and vendor cease to be members of the same group by reason of a transaction relating to shares in the vendor or another company that as a result of the transaction ceases to be a member of the same group as the purchaser.

Sub-paragraph 4ZA (1) of schedule 7 ensures that a vendor can still leave a group without triggering withdrawal of group relief, thus preserving the intention of the original legislation.

However, 4ZA (4) provides that it will no longer be possible to avoid the withdrawal of group relief where there is a subsequent change in control of the purchaser within three years of the transfer of the asset