111 Withdrawal of group relief

111  Withdrawal of group relief

(1)     This section applies where—

(a)     an instrument (“the relevant instrument”) transferring land in the United Kingdom from one company (“the transferor company”) to another (“the transferee company”) has been stamped on the basis that group relief applies,

(b)     before the end of the period of [three years] beginning with the date on which the instrument was executed the transferee company ceases to be a member of the same group as the transferor company, and

(c)     at the time when [the transferee company ceases] to be a member of the same group as the transferor company [it or a relevant associated company holds] an estate or interest in land—

(i)     that was transferred [to the transferee company] by the relevant instrument, or

(ii)     that is derived from an estate or interest that was so transferred,

[and that has not subsequently been transferred at market value by a duly stamped instrument on which ad valorem duty

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