A parent company with a 100% subsidiary is planning to purchase bare land from its wholly owned subsidiary with a view to eventually transferring the land as a distribution in specie to its shareholders; these consist of another company which has 60% of the shares of the parent, and an un-connected individual for whom we do not act. What are the stamp duty land tax (SDLT) and corporation tax implications for the transactions between the three companies involved?

The initial purchasing company can claim 100% relief from stamp duty land tax (SDLT) if the circumstances for group relief are met.