The partnership share attributable to the partner is zero unless:

(a)the effective date of the transfer of the relevant chargeable interest to the partnership was before 20 October 2003; or

(b)the effective date was on or after that date and either ad valorem stamp duty or SDLT was paid on the transfer.

The relevant chargeable interest is that which ceases to be partnership property as a result of the transfer or, if the transaction is the grant or creation of a chargeable interest, it is the chargeable interest out of which that interest is granted or created.

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