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Stamping on Partnerships

 
Kevin Griffin and Georgina West of Ernst & Young Stamp Taxes team take a first look at the draft legislation to bring partnerships into the SDLT fold
 
The consultative document published in April 2002 suggested that where there is a transfer of a substantial interest (30%) in certain entities (including partnerships whether onshore or offshore) whose major activity involves the exploitation of land and whose assets consist mainly of land (70% of the total gross assets) SDLT would be chargeable at the rates applicable to land (up to 4%). During the consultation period there was significant resistance from the professional and business community. It was felt that many bona fide entities (such as hoteliers and nursing homes) whose main asset was land could suffer unjustly under such a regime. It was also...

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