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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Special provisions relating to partnerships: Application of exemptions and reliefs

Consider a transfer of a chargeable interest from a partnership, whose partners are Company B and Company C) to another company (D) with which the partners are connected.

The transaction will be charged under Para18 and as a result of Para24 (transfer of chargeable interest from a partnership consisting wholly of bodies corporate) the chargeable consideration will be the market value of the interest transferred. NB this transfer will also be caught under FA03/S53, but Para 18 takes priority - see SDLTM34170.

However, if Companies B, C and D are group companies for the purposes of FA03/Sch7, the provisions of Sch7 Paras27 and 27A apply and group relief can be claimed if all conditions are met - see SDLTM34360.