Simon Howley overviews partnerships for stamp duty land tax purposes.
The stamp duty land tax (SDLT)â¯rules on property transactions which involve partnerships are inâ¯Schedule 15 to the Finance Act 2003. The rules can be divided into two parts, corresponding toâ¯Parts 2â¯andâ¯3 of that Schedule.
The first part deals with purchases by a partnership of property from, or sales by a partnership of property to, an outsider. That is simple enough; SDLTâ¯is levied on the price in the ordinary way. The second part deals with property transactions between a partner and their partnership, or inside partnerships, and is one of the most complex parts of theâ¯SDLTâ¯code. This article does not attempt to cover these complex rules, which is best saved for a series of future articles.
HMRC's guidance on SDLT and partnerships is included in its Stamp Duty Land Tax Manual at SDLTM33300
