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Home Forums Patrick Cannon Is SDLT payable on the transfer of capital interest in a partnership? Reply To: Is SDLT payable on the transfer of capital interest in a partnership?

#480
Patrick
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You’re correct in thinking that a retrospective election under para 12A would withdraw the benefit of para 10 on the original transfer to the LLP and avoid the para 14 issue on the transfers of the company’s interest in the LLP. However I don’t quite follow the reasoning in your second last para about the original interest transferred to the LLP being small. If the company sub-sold ?1m worth of property to the LLP then was not the interest transferred worth ?1m on which SDLT would be due in the absence of para 10?