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HMRC internal manual

Stamp Taxes on Shares Manual

Partnerships: Partnerships and partnership interests: definition of ‘partnership’

The statutory definition of the term ‘partnership’ is: ‘the relationship that subsists between persons carrying on business in common with a view to profit’ (section 1(1) of the Partnership Act 1890). A UK general or limited partnership is not a legal person except that Limited Liability Partnerships and Scottish partnerships are (see STSM091030). There is no stamp duty or Stamp Duty Reserve Tax legislation regarding the definition of a partnership.