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SLDT and Partnerships

Matthew Hutton Chartered Tax Adviser and Lecturer and Writer on SDLT discusses the regime for partnerships as revised by the Finance Act 2006
An article I wrote on the practical application of Finance Act 2003 Sch 15 to partnerships was published in The Tax Journal 12 September 2005 Issue 804. Substantial changes to the regime have been made by Finance Act 2006 and this article summarises both the present regime and the outstanding points of difficulty. All statutory references are to Sch 15 unless otherwise mentioned.
Anomalous and often counter-intuitive results can still follow to a large extent (though not exclusively) from the odd rule that an interest in a partnership is defined in terms of income- not capital-sharing ratios (para 34(2)).
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