SDLT and partnerships—transfers from a partnership
SDLT and partnerships—transfers from a partnership

The following Tax guidance note provides comprehensive and up to date legal information covering:

  • SDLT and partnerships—transfers from a partnership
  • Transfer of a chargeable interest from a partnership
  • Transfer from one partnership to another
  • Notification

This Practice Note explains the special stamp duty land tax (SDLT) rules which apply when an interest in land is transferred from a partnership to a partner or person connected with a partner, including transfers on dissolution of partnership.

Special SDLT rules apply:

  1. when a chargeable interest is transferred to a partnership from one or more partners or persons connected with one or more partners, including transfers on formation of the partnership

  2. when value is withdrawn from a partnership by certain parties during the three years following a transfer, as described in the bullet point above

  3. when a chargeable interest is transferred from a partnership to one or more partners or persons connected with one or more partners, including transfers in connection with the dissolution of the partnership, and

  4. when a chargeable interest is transferred from one partnership to another partnership and there are common or connected partners

The rules relating to special partnership transactions for SDLT purposes are set out in Part 3 of Schedule 15 to the Finance Act 2003 (FA 2003). Paragraph references throughout this Practice Note are to FA 2003, Sch 15 unless otherwise indicated.

This Practice Note explains the special SDLT rules which apply when a chargeable interest is transferred from a partnership to a partner or person connected with a partner, including transfers on dissolution of partnership. For