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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: Transfer of interest in a property investment partnership

A transfer to which this paragraph applies is a Type A transfer if it takes the form of arrangements entered into under which—

  1. the whole or part of a partner’s interest as partner is acquired by another person (who may be an existing partner), and
  2. consideration in money or money’s worth is given by or on behalf of the person acquiring the interest.

A transfer to which this paragraph applies is also a Type A transfer if it takes the form of arrangements entered into under which—

  1. a person becomes a partner,
  2. the interest of an existing partner in the partnership is reduced or an existing partner ceases to be a partner, and
  3. there is a withdrawal of money or money’s worth from the partnership by the existing partner mentioned in paragraph (b) (other than money or money’s worth paid from the resources available to the partnership prior to the transfer).

Any other transfer to which Para14 applies is a Type B transfer. In other words, any transfer that is not a Type A transfer, is a Type B.

As noted elsewhere, whether the transfer is categorised as a Type A or a Type B affects what chargeable interests are taken into account as relevant partnership property - see SDLTM34030.