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HMRC internal manual

Stamp Duty Land Tax Manual

From
HM Revenue & Customs
Updated
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Special provisions relating to partnerships: Definitions

Section 1122 Corporation Taxes Act 2010 has effect for the purposes Part 3 except that,

  • Section 1122 has effect with the omission of subsection (7) (partners connected with each other) and
  • for the purposes of calculating the sum of the lower proportions in Para12/Para20 [see SDLTM33560], Section 1122 has effect with the omission of subsection (6)(c to e) (trustee connected with settlement).

So, for the purposes of Part 3, partners are not connected with each other solely by being members of the partnership