A reconstruction may fail to achieve a complete exemption from SDLT under para. 7 but may qualify for relief under para. 8. SDLT at a rate of 0.5 per cent is payable (as opposed to a rate of up to 4 per cent) where an acquiring company acquires the whole or part of the undertaking of another company (the target company) provided certain conditions are met (see 80-300). These conditions are:
(i)The consideration for the acquisition consists of or includes the issue of non-redeemable shares in the acquiring company to the target company or all or any of its shareholders.