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HMRC internal manual

Stamp Duty Land Tax Manual

Special provisions relating to partnerships: Example of the application of the special provisions


A, B, C & D are in partnership, with a 25% share each in the income profits (Para 34).

A brings a property into the partnership worth £1m subject to a £250,000 mortgage which is secured on it. A is paid £500,000 by the partnership.

SDLT is calculated in accordance with Paras10 & 12 on the market value and the sum of the lower proportions (SLP) [see SDLTM33560].

In this case the SLP is 25 so that the charge is on 75% of the market value which is £750,000. The actual consideration and any related debt is ignored for the purposes of Para10.