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HMRC internal manual

Stamp Duty Land Tax Manual

Special provisions relating to partnerships: Application of exemptions and reliefs

Where the conditions for Charities relief under FA03/Sch8 are met the relief applies to all partnership transactions. However, this is modified where para14 (transfer of interest in property investment partnership) or para17 (transfer of a partnership interest pursuant to earlier arrangements) applies.

For para14 purposes the transferee must be a charity and every chargeable interest held as partnership property immediately after the transfer must be held for qualifying charitable purposes (Para 28(2) &(3)).