31 August 2026 · Which Relief
Restructuring vs Qualifying Group Relief
Article 27 business restructuring relief covers the transfer of a whole business or an independent part in mergers and reorganisations. Article 26 Qualifying Group Relief covers transfers of assets and liabilities between companies in the same 75%+ common-ownership group. Both are broadly no gain / no loss and both carry a two-year clawback. Which you use depends on whether you are moving a business or moving assets within a group.
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For business transfers
Use it for mergers and reorganisations.
- Transfer a whole business or independent part.
- Consideration usually in shares.
- For mergers, spin-offs, reorganisations.
- No gain / no loss, 2-year clawback.
For group asset transfers
Use it within a 75% group.
- Transfer of assets/liabilities within a group.
- 75%+ common-ownership link required.
- Both parties resident and aligned.
- No gain / no loss, 2-year clawback.
Related guides
Frequently Asked Questions
For picking the right relief.
When do I use Article 26 instead of 27?
Use Article 26 Qualifying Group Relief for transfers of assets/liabilities within a 75%+ group; use Article 27 for transferring a whole business or independent part.
Do both have a clawback?
Yes, both carry a two-year clawback if the structure is broken by an onward disposal.
What common-ownership level does Article 26 need?
A 75% or greater common-ownership link between the companies.
Can Exiloz pick the right relief?
Yes. We identify whether Article 26 or 27 fits your transaction.
Pick the right relief
Exiloz tells you whether Article 26 or Article 27 fits your restructuring.