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HMRC internal manual

Stamp Taxes on Shares Manual

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HM Revenue & Customs
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Partnerships: Partnerships and partnership interests: overview

There are two aspects to the taxation of partnerships. Firstly, at the top level there is the treatment of transactions involving partnership interests. Secondly, there is the treatment of transactions entered into by the partnership. This chapter is largely about the former, including partnership formation, dissolution and transfers of partnership interests. However, it also contains references to how partnerships are treated when conducting ‘normal’ transactions (see STSM093000+)

Following the introduction of Stamp Duty Land Tax on 1 December 2003, the scope of stamp duty is limited to instruments transferring stock or marketable securities and certain partnership interests (see FA03/S125 and FA03/SCH15/PARA31 (1)). See STSM091050 on the transfer of partnership interests.