104. Liability of partnership to stamp duty and stamp duty land tax.

On normal principles, ad valorem stamp duty will be chargeable upon partners where they execute a deed or other document in order to effect a conveyance or transfer of any partnership asset, whether during the currency of the partnership or on its dissolution1. For the purposes of stamp duty land tax, a chargeable interest held on behalf of a partnership is treated as held by or on behalf of the partners and a land transaction entered into for the purposes of a partnership is treated as entered into by or on behalf of all of the partners

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