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HMRC internal manual

Stamp Duty Land Tax Manual

Special provisions relating to partnerships: Acquisition of an interest in a partnership Para29

Transfers of an interest in a partnership other than a property investment partnership are, in general, not deemed to be land transactions for the purposes of Stamp Duty Land Tax (SDLT).

The only occasions on which a transfer of an interest in a partnership attracts SDLT are certain acquisitions of an interest in

  • a property investment partnership (Para14) or
  • any partnership following a transfer caught by Para17 and 17A

As a result the purchase of an interest in a farming partnership, for example, will not be chargeable to SDLT provided that

  1. farming partnership does not fall within the definition of a property investment partnership (Para14) see SDLTM34030 and
  2. there has not previously been a transfer to the partnership and the provisions of Paras17 or 17A do not apply.