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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

For the purposes of FA03/Sch15 generally, partnership share at any time refers to the proportion in which the partner is entitled at that time to share in the income profits of the partnership in accordance with Para34(2)

There are, however, specific additional rules that determine the partnership share to be used in the calculation of the sum of the lower proportions for the purposes of Para20. These can be found in Paras21 and 22. We are working on further guidance here which will be incorporated as soon as possible.