The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
The SDLT treatment of partnership transactions is notorious as one of the most complex areas of tax. The rules have been in place for many years albeit there remain a number of important concepts over which there is little guidance and no case law. In this article we will look at some examples which set out how the rules work and hopefully illustrate some of the issues which practitioners have to deal with.
It should be noted that similar rules apply in Scotland and Wales – but there are material differences in both jurisdictions such that it is necessary to consider the rules separately. This article refers only to SDLT.
The relevant SDLT partnerships legislation is primarily set out in FA...
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The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
The SDLT treatment of partnership transactions is notorious as one of the most complex areas of tax. The rules have been in place for many years albeit there remain a number of important concepts over which there is little guidance and no case law. In this article we will look at some examples which set out how the rules work and hopefully illustrate some of the issues which practitioners have to deal with.
It should be noted that similar rules apply in Scotland and Wales – but there are material differences in both jurisdictions such that it is necessary to consider the rules separately. This article refers only to SDLT.
The relevant SDLT partnerships legislation is primarily set out in FA...
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:
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