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Where Taxpayers and Advisers Meet

SDLT on reconstruction

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Joined:Thu Feb 23, 2012 10:26 am
SDLT on reconstruction

Postby Feedback » Tue Aug 11, 2015 5:34 pm

limco X is owned by Mr A, Mr B, Mr C and Mr D all in equal shares.

limco Y is owned 50% by limco A and 50% by Mr E

limco Z is owned 70% by limco A and 30% by Mr F

If the business is reconstructed so that limco X wholly owns Y and Z and in lieu of their shares in Y and Z, Mr E and Mr F respectively are given shares in limco X approximately in line with their values of shares held, does this come under reconstruction relief under s75/77 FA86?

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