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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Land and buildings, machinery and plant: Property used by a partnership

In relation to any land or building, machinery or plant used by a partnership, IHTA84/S105 (1)(d) may apply to assets owned by the transferor. For example, both the following types of transfer may be eligible for relief under this paragraph:

  • a transfer of a qualifying asset owned by the partner outside the partnership but used by the partnership, and
  • a transfer by a partner of his interest in a qualifying asset which is owned by the partnership (but in Scotland, because of the different nature of a Scottish partnership, it is doubtful if a partner is able to transfer his interest in an asset that was owned by the partnership).