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Jurisdiction(s):
United Kingdom
Key definition
Group relief definition

What does Group relief mean? group relief is a corporation tax mechanism that lets one group company surrender specified losses or reliefs to another to reduce the claimant company’s taxable profits for overlapping accounting periods. It is legislated in the UK (Corporation Tax Act 2010, including the post‑2017 carried‑forward loss rules) and Ireland (Taxes Consolidation Act 1997, ss.420–423). Key features: - Available only where both the surrendering and claimant companies are within the charge to corporation tax and in the same 75% group throughout the relevant periods (with separate rules for consortium relief). - Surrenderable amounts typically include current‑period trading losses, non‑trading deficits on loan relationships,...

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SDLT Group Relief: Eligibility, 75% Group Tests, Claims, Anti-avoidance, and Clawback (England and Northern Ireland)

Published by a LexisNexis Tax expert
Practice notes
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Generally, subject to any exemptions or reliefs, acquiring a chargeable interest in land (a land transaction), including the grant of a leasehold interest, is ordinarily subject to stamp duty land tax (SDLT). An exemption from SDLT can be claimed where:

  • the land transaction is entered into between two separate corporate bodies that, at the SDLT‑effective date of the transaction (usually completion), are members of the same SDLT group
  • the anti‑avoidance provisions do not operate to deny relief, and
  • it is duly claimed on the land transaction return, SDLT1, using code 12

Although no supporting documents accompany the claim, the purchasing claimant must still keep evidence to demonstrate its entitlement to it, since HMRC may enquire into the validity of the relief claim up to nine months after:

  • the filing date of the land transaction return (ie due date for filing a return), if the return is delivered on or before that date
  • the date on which the land transaction return was delivered (if delivered after the filing date), or
  • the date on which an amendment to the land transaction return was made (where amended by the purchaser under FA 2003, Sch 10, para 6)...
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Web page updated on 21/05/2026

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