As stated at ¶400-500, for stamp duty to be chargeable on an instrument effecting the transfer of a partnership interest, the ‘relevant partnership property’ must include some ‘relevant securities’ (FA 2003, Sch. 15, para. 33(1A)).

‘Relevant partnership property’ is the partnership property immediately after the transfer of the partnership interest, other than any partnership property that was transferred to the partnership in connection with the transfer (FA 2003, Sch. 15, para. 33(3A)).

‘Relevant securities’ are stock or marketable securities other than growth-market shares (FA 2003, Sch. 15, para. 33(8A)).

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

No subscription?

Contact us to discuss your requirements.