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Home Forums Patrick Cannon SDLT Partnerships Sch. 15 FA2003 SLP Reply To: SDLT Partnerships Sch. 15 FA2003 SLP

#5116
AJ Mussell
Keymaster

James, you are correct to be sceptical. The partnership share for these purposes is the share of trading profit not capital: see https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm33400 The reason given to me by HMRC many years ago was that they thought that the share of trading profit was less open to manipulation than the share of capital.