SDLT and partnerships

SPEED READ The legislation relating to SDLT and partnerships has already had a chequered history. Even the analysis of fairly common commercial transactions may require the resolution of complexities which can appear vastly disproportionate to the amount of tax concerned. HMRC have now published guidance on the subject, which is a helpful commentary but does not answer all the difficult questions that arise in practice. Some of these relate in particular to the application of the rules to open-ended investment partnerships, and the widely drawn anti-avoidance legislation in the area.