SDLTM23081a | Reliefs: Group, reconstruction or acquisition relief

In the group of H, P and V, V transfers a property intra group to P and group relief is claimed (the qualifying conditions are met). V then leaves the group. Although P is no longer part of the same group as V, group relief is not withdrawn at this stage. This maintains the position pre FA 2008

Two years after the purchase by P, H sells its shares in P to an unconnected third party. This change in control of P will now trigger withdrawal of the original group relief.

Withdrawal of group relief would similarly be triggered if there was a change in the control of H as this effectively changes the control of P.