The recent stamp duty land tax (SDLT) Upper Tribunal case of The Tower One St George Wharf Ltd v HMRCopens in a new tab [2024] UKUT 373 (TCC) upheld the First-tier Tribunal (FTT) decision that:
- SDLT group relief was not available on a group transfer because it formed part of arrangements of which a main purpose was the avoidance of corporation tax; and
- The distribution exemption from the connected persons market value charge did not apply where a claim for group relief had been made in the three years prior to the time of the distribution.
Legislative references are to Finance Act 2003.