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Contents

Official guidance
Stamp Duty Land Tax Manual

SDLTM34000 · Special provisions relating to partnerships: Transfer of interest in a Property Investment partnership

  • SDLTM34010 · Para 14 - Overview
  • SDLTM34020 · Type A/Type B - Para 14(3A-3C)
  • SDLTM34030 · Relevant partnership property - Para 14 (5-5A)
  • SDLTM34040 · Certain leases not relevant partnership property - Para 15
  • SDLTM34050 · Transfer of interest in a property investment partnership - Example
  • SDLTM34060 · Election by property investment partnership to dis-apply, Para 10 - Para 12A
  1. Special provisions relating to partnerships: Transfer of interest in a Property Investment partnership: contents
  2. Type A/Type B - Para 14(3A-3C)

SDLTM34020 | Type A/Type B - Para 14(3A-3C)

From HM Revenue & Customs · Stamp Duty Land Tax Manual

A transfer of an interest in a property investment partnership is a Type A transfer if it takes the form of arrangements entered into under which—

  1. the whole or part of a partner’s interest as partner is acquired by another person (who may be an existing partner), and

  2. consideration in money or money’s worth is given by or on behalf of the person acquiring the interest.

A transfer of an interest in aproperty investment partnership is also a Type A transfer if it takes the form of arrangements entered into under which—

  1. a person becomes a partner,

  2. the interest of an existing partner in the partnership is reduced or an existing partner ceases to be a partner, and

  3. there is a withdrawal of money or money’s worth from the partnership by the existing partner mentioned in paragraph (b) (other than money or money’s worth paid from the resources available to the partnership prior to the transfer).

Any other transfer to which Para14 applies is a Type B transfer. In other words, any transfer of an interest in a property investment partnership that is not a Type A transfer, is a Type B.

As noted elsewhere, whether the transfer is categorised as a Type A or a Type B affects what chargeable interests are taken into account as relevant partnership property - see SDLTM34030.

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