Kevin Ashman and Aaron Burchell review some key SDLT issues for transactions involving partnerships, on which HMRC have recently published guidance
In its relatively short the SDLT code has yielded a considerable amount of critical commentary and a commensurate amount of legislative re-drafting.
The SDLT rules applying to partnerships (first introduced by FA 2004 as FA 2003 Sch 15) are among the most complex elements of this area and have the dubious distinction of being partly responsible (in their interaction with the sub-sale provisions) for one of the very few tribunal decisions on SDLT (DV3 RS Ltd Partnership v HMRC ([2011] TC01012)).
HMRC’s guidance
HMRC have in March 2011 published guidance on SDLT and partnerships as an additional chapter to their SDLT Manual (see SDLTM33000 onwards). It is a measure of the complexity of the area that HMRC previously issued two forms of draft guidance; the latter...
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Kevin Ashman and Aaron Burchell review some key SDLT issues for transactions involving partnerships, on which HMRC have recently published guidance
In its relatively short the SDLT code has yielded a considerable amount of critical commentary and a commensurate amount of legislative re-drafting.
The SDLT rules applying to partnerships (first introduced by FA 2004 as FA 2003 Sch 15) are among the most complex elements of this area and have the dubious distinction of being partly responsible (in their interaction with the sub-sale provisions) for one of the very few tribunal decisions on SDLT (DV3 RS Ltd Partnership v HMRC ([2011] TC01012)).
HMRC’s guidance
HMRC have in March 2011 published guidance on SDLT and partnerships as an additional chapter to their SDLT Manual (see SDLTM33000 onwards). It is a measure of the complexity of the area that HMRC previously issued two forms of draft guidance; the latter...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")