List of Public Bodies in England and Wales for Transfer Reliefs

SDLT relief for transfers involving certain public bodies in England and Wales

Some land transactions can qualify for Stamp Duty Land Tax relief if they involve a recognised public body in England or Wales. The key point is to check the exact legal entity involved, because relief depends on whether that body is specifically listed, or fits a statutory category in the official rules, and not simply on whether it has a public sector role.

• The official list covers certain government and parliamentary bodies, local authorities, health bodies, and other authorities that qualify as local planning authorities.
• You must identify the precise legal person buying or selling the land, not just rely on its public funding or general public function.
• A council-owned company or other related entity is not automatically treated in the same way as the council itself.
• If a body is not named directly, you should check whether it falls within one of the statutory descriptions and was created under the relevant legislation.
• Being a listed public body only answers the first question; the separate conditions for the SDLT relief must still be met.

Scroll down for the full analysis.

SDLT relief for transfers involving certain public bodies in England and Wales

This page explains a specific Stamp Duty Land Tax point: which public bodies in England and Wales fall within the official list for transfers involving public bodies. The source material is brief, but it matters because SDLT reliefs that apply to public bodies depend on whether the buyer, seller, or other party is one of the bodies named in the legislation or guidance.

What this rule is about

Some land transactions involving public bodies can qualify for SDLT relief. A basic first step is to identify whether the organisation involved is actually one of the recognised public bodies for this purpose.

The source material does not set out the full relief conditions. Instead, it provides a list of public bodies situated in England and Wales. In practice, that list is used to determine whether a transaction is even capable of falling within the relevant public body rules.

This means the issue is not simply whether an organisation performs a public function. The more precise question is whether it is one of the bodies listed, or falls within one of the listed statutory descriptions.

What the official source says

The official material lists the following public bodies in England and Wales:

• Government and parliamentary bodies, including a Minister of the Crown, the National Assembly for Wales Commission, the Corporate Officer of the House of Lords, the Corporate Officer of the House of Commons, and the Welsh Ministers, the First Minister for Wales, and the Counsel General to the Welsh Assembly Government.
• Local government bodies, including county and district councils, county and county borough councils, London borough councils, the Greater London Authority, the Common Council of the City of London, and the Council of the Isles of Scilly.
• Health bodies, including certain Strategic Health Authorities, Health Authorities, Special Health Authorities, Primary Care Trusts, Local Health Boards, and NHS Trusts created under the statutory provisions named in the source.
• Any other authority that is a local planning authority within the meaning of the Town and Country Planning Act 1990.

The source is therefore defining the bodies that count as public bodies for this part of the SDLT rules, rather than explaining the full tax treatment by itself.

What this means in practice

If a land transaction involves one of these bodies, you should consider whether a public body relief may apply. If the organisation is not on the list and does not fall within one of the statutory categories mentioned, the relief may not be available on this particular basis.

This matters because public sector transactions are often carried out through a range of entities. Some are clearly listed, such as a London borough council or an NHS Trust. Others may be connected to government or funded by the public sector but still not fall within this list.

For example, an arm’s length company owned by a council is not automatically the same thing as the council itself. Likewise, a body carrying out public functions is not necessarily a listed public body unless it fits one of the statutory descriptions in the source.

The practical effect is that you should identify the exact legal person acquiring or disposing of the land. The name used in correspondence or the fact that the body is publicly funded is not enough on its own.

How to analyse it

A sensible way to approach this issue is:

• Identify the exact legal entity involved in the land transaction.
• Check whether that entity is expressly named in the official list.
• If it is not expressly named, check whether it falls within one of the statutory descriptions, such as being a local planning authority within the meaning of the Town and Country Planning Act 1990.
• If the body is part of the health sector or local government, confirm that it was established under the legislation referred to in the source.
• Only after confirming the body is within the list should you move on to the separate question of whether the transaction satisfies the conditions for any SDLT relief.

That last step is important. Being a listed public body does not by itself guarantee relief. It only answers the threshold question of whether the transaction involves a qualifying type of body.

Example

Illustration: a parcel of land is transferred to a London borough council as part of a local authority reorganisation. The council is one of the bodies listed in the official material, so the transaction passes the first stage of the analysis for a public body relief. The next question would be whether the specific statutory conditions for the relief are met.

By contrast, if the land is transferred to a separate company owned by that council, you cannot assume the same result. The company would need to be considered in its own legal capacity, and the source material does not say that all council-owned entities are covered.

Why this can be difficult in practice

The source is a list, not a full explanation. That creates a few practical difficulties.

• The names and structures of public bodies can change over time. A transaction may involve a successor body, a restructured authority, or an entity operating under a different statutory framework.
• Some bodies are covered by description rather than by name. For those, you need to check the underlying legislation carefully.
• There can be confusion between a public authority itself and related entities such as subsidiaries, joint ventures, development vehicles, or outsourced bodies.
• The source does not state the substantive relief conditions, so readers may wrongly assume that being on the list is enough. It is not.

In short, the key difficulty is classification. The legal identity of the party matters more than its public sector connection in a general sense.

Key takeaways

• This official material identifies which public bodies in England and Wales count for this part of the SDLT rules.
• The first question is whether the actual legal entity involved is one of the listed bodies or falls within a listed statutory category.
• Being a listed public body is only the starting point; any SDLT relief still depends on the separate conditions for that relief being met.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: List of Public Bodies in England and Wales for Transfer Reliefs

View all HMRC SDLT Guidance Pages Here