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HMRC internal manual

Stamp Duty Land Tax Manual

From:
HM Revenue & Customs
Published:
Updated:
, see all updates

  1. Contents
  2. SDLTM30000
  3. SDLTM33300
  4. SDLTM34000
  5. SDLTM34030

Special provisions relating to partnerships: Transfer of interest in a property investment partnership

What property is taken into account when calculating the chargeable consideration depends on whether the transfer is a Type A transfer or a Type B transfer.

Relevant partnership property in relation to a Type A transfer of an interest in a partnership, is every chargeable interest held as partnership property immediately after the transfer, other than

  1. any chargeable interest that was transferred to the partnership in connection with the transfer;
  2. a lease to which Para15 (exclusion of market rent leases) applies, and
  3. any chargeable interest that is not attributable economically to the interest in the partnership that is transferred.

Relevant partnership property in relation to a Type B transfer of an interest in a partnership, is every chargeable interest held as partnership property immediately after the transfer, other than

  1. as above
  2. as above
  3. as above
  4. any chargeable interest that was transferred to the partnership on or before 22 July 2004,
  5. any chargeable interest in respect of whose transfer to the partnership an election has been made under Para12A, and
  6. any other chargeable interest whose transfer to the partnership did not fall within Para10(1)(a)-(c).
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