Revenue eBrief No. 142/24
21 May 2024
Stamp Duty Manual - Part 7: Section 79 Conveyances and transfers of property between certain bodies corporate - Updated
Section 79 of the Stamp Duties Consolidation Act 1999 provides for a stamp duty exemption to apply on certain instruments that have the effect of conveying or transferring a beneficial interest in property between associated bodies corporate. The exemption is generally referred to as ‘associated companies’ relief’.
Tax and Duty Manual Section 79 - Conveyances and transfers of property between certain bodies corporate has been revised and refreshed throughout to make it easier to follow. Furthermore, additional guidance has been added under the heading Section 5.3.1 “Alternative conditions in the guidance” to clarify the treatment that may apply in the case of a merger of a trade where relief is claimed in respect of assets that are naturally be used during the course of the trade (e.g., trading stock, plant and equipment) and cannot therefore meet the two-year holding requirement.