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Readers’ forum: Is stamp duty payable on the transfer of company property?

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25 October 2022
Issue: 4862 / Categories: Forum & Feedback
Is stamp duty payable on the transfer of company property?

Stamp duty land tax

My client has holding company Company A which is a trading company with an approximate value of £2m. It has a 100% trading subsidiary (Company B with an approximate value of £1m).

Shares in the holding company are 100% owned by one shareholder Mrs Z who is UK resident and domiciled.

We did a direct statutory demerger under CTA 2010 s 1076 and as a result the above two companies are now stand alone trading companies ie instead of Mrs Z owing shares in just the holding company (Company A) she now owns 100% of the shares directly in the holding company (trading co) and also 100% shares directly in Company B (trading co).

No money has changed hands to Mrs Z. This transaction is for bona fide commercial purposes due to regulatory reasons. We did obtain HMRC clearance and...

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