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Contents

Official guidance
Stamp Duty Land Tax Manual

SDLTM20000 · Reliefs

  • SDLTM20010 · Introduction
  • SDLTM20200 · Freeports and Investment Zones relief
  • SDLTM20500 · Diplomatic premises
  • SDLTM20600 · Sovereign Bodies and International Organisations
  • SDLTM20700 · Zero carbon homes relief
  • SDLTM21000 · Certain acquisitions of residential property
  • SDLTM21500 · Pre-completion transaction
  • SDLTM22000 · Compulsory purchase facilitating development
  • SDLTM22500 · Compliance with planning obligations
  • SDLTM23000 · Group, reconstruction or acquisition relief
  • SDLTM23500 · Demutualisation of insurance company
  • SDLTM24000 · Demutualisation of building society
  • SDLTM24500 · Incorporation of limited liability partnerships
  • SDLTM24700 · Seeding relief for Co-ownership Contractual Schemes & PAIFs: Contents
  • SDLTM25000 · Transfers involving public bodies
  • SDLTM25500 · Transfers in consequence of reorganisation of parliamentary constituencies
  • SDLTM26000 · Charities relief
  • SDLTM26500 · Acquisition by bodies established for national purposes
  • SDLTM27000 · Right to buy transactions, shared ownership leases etc
  • SDLTM27500 · Certain acquisitions by registered social landlords
  • SDLTM27510 · Supplementary Information FA03/S71
  • SDLTM28000 · Alternative property finance
  • SDLTM28500 · Exercise of collective rights by tenants of flats
  • SDLTM29000 · Crofting community right to buy
  • SDLTM29200 · Financial Institutions in Resolution
  • SDLTM29500 · Arrangements involving public or educational bodies
  • SDLTM29600 · Miscellaneous provisions
  • SDLTM29800 · First Time Buyers
  • SDLTM29900 · Relief for transfers involving multiple dwellings
  • SDLTM20050 · Disadvantaged areas relief
  • SDLTM23082 · Group, reconstruction or acquisition relief
  • SDLTM23200 · Group, reconstruction or acquisition relief
  1. Reliefs: Contents
  2. Reliefs: Incorporation of limited liability partnerships

SDLTM24500 | Reliefs: Incorporation of limited liability partnerships

From HM Revenue & Customs · Stamp Duty Land Tax Manual

General overview FA03/S65

Where the following three conditions are met, relief from Stamp Duty Land Tax may be claimed on a land transaction which transfers a chargeable interest from a person (the transferor) to a limited liability partnership in connection with its incorporation.

A limited liability partnership means one formed under the Limited Liability Partnerships Act 2000 or the Limited Liability Partnerships Act (Northern Ireland) 2002.

The three conditions are that:

Content shown with reduced fidelity

the effective date of the land transaction is within the period of one year from the date of incorporation of the limited liability partnership at the relevant time the transferor is a partner in a partnership comprised of all the persons who are (or are to be) members of the limited liability partnership (and no-one else) or holds the chargeable interest transferred as nominee or bare trustee for one or more or the partners in such a partnership any differences in the proportions of the interest held by the partners before and after the transaction have not arisen as part of a scheme or arrangement the main purpose (or one of the main purposes) of which, is the avoidance of liability to any duty or tax.

Relevant time means

  • if the transferor acquired the chargeable interest after the partnership was incorporated, the time immediately after they acquired that chargeable interest

  • otherwise, immediately before the partnership was incorporated

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