Background and introduction

This relief, which did not feature in the original Act, is somewhat of an anomaly in this grouping in that it was born out of an anti-avoidance measure. It was enacted in reaction to the wholesale reform of the SDLT subsale reliefs, which were routinely abused to avoid the incidence of tax altogether. One therefore needs to understand the SDLT background in order to appreciate the purpose and nature of the LBTT relief.

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