Does SDLT apply to transfers between connected companies?

[tony]

A Hong Kong company owns the shares in a UK company 30 years ago and which owns 3 uk properties bought 30 years ago no borrowings.
HK co wants to transfer the 3 UK properties into 3 seperate IoM companies.
does SDLT bite or can bona fide De-grouping provisions apply?

[Patrick]

Tony, if the three IoM companies are part of the HK company’s group then in principle SDLT group relief can be claimed. You might also be able to insert the three companies above the UK company and then distribute the three properties pro rata to the shareholdings. Other taxes would however need to be considered.

[Author]

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