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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Special provisions relating to partnerships: Transfers of a chargeable interest from a partnership

Example 1

A partnership owns a chargeable interest (a freehold property, for example) which it wishes to transfer to a partner, individual A. There are two other partners, individuals B and C. None of the partners are connected to each other for the purposes of schedule 15. Partner A’s partnership share is 30%.

The sum of the lower proportions calculated in accordance with Para20 is 30 - see SDLTM33750. As a result, the chargeable consideration for the purposes of SDLT is (100-30) %, that is 70%.

This equates to the additional proportion of the chargeable interest acquired by Partner A which is identical to the proportion of the chargeable interest previously held by Partners B and C through their interest in the partnership.