SolvedSDLTM33410 | Connected persons - Para39
From HM Revenue & Customs · Stamp Duty Land Tax Manual
Section 1122 Corporation Taxes Act 2010 has effect for the purposes Part 3 except that,
Section 1122 has effect with the omission of subsection (7) (partners connected with each other) and
for the purposes of calculating the sum of the lower proportions in Para12/Para20 [see SDLTM33560], Section 1122 has effect with the omission of subsection (6)(c to e) (trustee connected with settlement).
So, for the purposes of Part 3, partners are not connected with each other solely by being members of the partnership. The omission of section 1122(6)(c to e) ensures that the anti-avoidance provisions in Para 12/20 are correctly targeted.