Nigel Popplewell of Burges Salmon LLP reviews the impact of recent changes to the SDLT regime which applies to partnerships
When stamp duty land tax (SDLT) was introduced by the Finance Act 2003 the schedule (Sch 15) dealing with SDLT and partnerships was left unfinished. It comprised 12 paras of which the following are of note. Firstly paragraph 2 entitled 'Legal Personality of Partnership Disregarded' provided inter alia that 'a chargeable interest held by or on behalf of a partnership is treated as held by or on behalf of the partners …'. This treated the partnership as transparent identifying a partner's share of the underlying land with his income interest.
Secondly paras 9 to 12 exempted various...
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Nigel Popplewell of Burges Salmon LLP reviews the impact of recent changes to the SDLT regime which applies to partnerships
When stamp duty land tax (SDLT) was introduced by the Finance Act 2003 the schedule (Sch 15) dealing with SDLT and partnerships was left unfinished. It comprised 12 paras of which the following are of note. Firstly paragraph 2 entitled 'Legal Personality of Partnership Disregarded' provided inter alia that 'a chargeable interest held by or on behalf of a partnership is treated as held by or on behalf of the partners …'. This treated the partnership as transparent identifying a partner's share of the underlying land with his income interest.
Secondly paras 9 to 12 exempted various...
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