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HMRC internal manual

Stamp Duty Land Tax Manual

Example 10, Partnerships

  • A enters into a sale and purchase agreement with B for some land with a consideration of £1 million which reflects the market value of the land.
  • B enters into a subsale agreement with C for consideration of £1 million. C is a partnership in which B has a 90 per cent partnership share. The two agreements complete at the same time and in connection with each other.

B is chargeable on its acquisition of the land and can claim relief.

C is chargeable on its acquisition of the land. The chargeable consideration given by paragraph 9 (as it applies to paragraph 1 of Schedule 4) is £1 million. C does not get the benefit of the rules for special partnership transactions in Part 3 of Schedule 15 because the vendor for C’s acquisition is A (paragraph 10(4)).