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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Application of exemptions and reliefs: Group Relief

English Partnerships (EP) and English Limited Partnerships (ELP)

A Ltd owns 100% of the issued share capital of B Ltd and C Ltd.

B Ltd and C Ltd own a 50% each partnership interest in ‘The Partnership’.

The partnership owns 100% of the issued share capital in E Ltd and F Ltd.

Where ‘The Partnership’ in the structure above is an English Partnership (EP) or an English Limited Partnership (ELP).