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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

As example 1 at SDLTM33850 but the property is transferred to Company X.

Step One

Identify the relevant owner or owners.

Company X is a relevant owner because, immediately after the transaction, it is entitled to a proportion of the chargeable interest and immediately before the transaction it was connected to a partner.

Step Two

For each relevant owner, identify the corresponding partner or partners.

There are no corresponding partners as Company X was not a partner and Company A and Company B are not an individuals so the test at Step Two (b) is not met.

Therefore the SLP = 0

As the lower proportion is less than 75, Para 24 does not apply so the chargeable consideration is 100% of the market value i.e. £5m.The availability of group relief will depend on the status of the partnership and the provisions of para27 - see SDLTM34360.