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A& B are brothers. A is dying. B is to buy A’s entire interest in land and buildings A&B own as a property investment partnership. B is not buying A’s “interest” in the partnership, as the partnership is terminating. Para 18(2)+ Para 20 imply no SDLT. As the actual transaction is a sale of land for full value, why should no duty be payable?
I agree no SDLT and the reason is the policy of treating transfers between person connected with individual partners as generally not taxable.
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