A Ltd (the vendor) owns a property and sells it to B Ltd (the
purchaser).
The effective date of this land transaction is 12/06/04.
At 12/06/04, both A Ltd and B Ltd satisfy the requirements
for group relief as B Ltd is a 100% subsidiary of A Ltd and all the
other tests are fulfilled.
However, on 12/06/04, an arrangement is made for A Ltd to
sell the shares in B Ltd to an unconnected, third party, company (C
Ltd).
Group relief is not available to B Ltd because this
arrangement would mean that C Ltd would obtain control of B Ltd but
not of A Ltd.
B Ltd would have to pay Stamp Duty Land Tax and make a land
transaction return.
