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HMRC internal manual

Stamp Duty Land Tax Manual

How is a partnership treated for SDLT purposes: Partnership personality disregarded - Para2

For the purposes of SDLT,

  • a chargeable interest held by or on behalf of a partnership is treated as held by or on behalf of the partners, and
  • a land transaction entered into for the purposes of a partnership is treated as entered into by or on behalf of the partners, and not by or on behalf of the partnership as such.

These provisions apply notwithstanding that the partnership is regarded as a legal person, or as a body corporate, under the law of the country or territory under which it is formed.