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HMRC internal manual

Stamp Taxes on Shares Manual

Partnerships: Changes in a partnership: merger of partnerships

The stamp duty implications of a merger of partnerships will depend on the form of the merger. If the merger is structured as the sale or exchange of partnership interests then stamp duty is likely to arise on the transfer on sale of a partnership interest (see STSM091050). However, if the merger is structured as the creation of a new partnership into which is contributed the businesses of the existing partnerships, then the transactions may be more likely to be treated as contributions to a new partnership (see STSM092010).