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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

Para 24 applies where:

  1. there is a transaction to which Para18 (transfer of a chargeable interest from a partnership) applies;
  2. immediately before the transaction all the partners are bodies corporate;
  3. the sum of the lower proportions, determined in accordance with Para20, is 75 or more.

Where Para24 applies, Para18 is amended so that the chargeable consideration for the transaction shall be taken to be equal to the market value of the interest transferred.

Where Para 24 applies, Para19 is also amended.