Q&As

When establishing whether transactions are linked for stamp duty land tax purposes, HMRC guidance directs us to section 1122 of the Corporation Tax Act 2010. Are limited liability partnership’s covered by this definition?

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Produced in partnership with Mary Ashley of Old Square Tax Chambers
Published on LexisPSL on 26/05/2020

The following Tax Q&A produced in partnership with Mary Ashley of Old Square Tax Chambers provides comprehensive and up to date legal information covering:

  • When establishing whether transactions are linked for stamp duty land tax purposes, HMRC guidance directs us to section 1122 of the Corporation Tax Act 2010. Are limited liability partnership’s covered by this definition?

When establishing whether transactions are linked for stamp duty land tax purposes, HMRC guidance directs us to section 1122 of the Corporation Tax Act 2010. Are limited liability partnership’s covered by this definition?

Section 108 of the Finance Act 2003 (FA 2003) defines a linked transaction. In particular, FA 2003, s 108(1) provides:

‘Transactions are ‘linked’ for the purposes of this part if they form part of a single scheme, arrangement or series of transactions between the same vendor and purchaser or, in either case, persons connected with them. Section 1122 of the Corporation Tax Act 2010 (connected persons) has effect for the purposes of this subsection.’

Section 1122 of the Corporation Tax Act 2010 (CTA 2010) does not directly address limited liability partnerships (LLPs) for these purposes.

LLPs are, however, addressed in section 1273 of the Corporation Tax Act 2009 (CTA 2009), which provides that:

‘…(2) For all purposes, except as otherwise provided, in the Corporation Tax

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