ABSTRACT
Partnership transactions can take on various forms. This is recognised in the legislation, and extensive provisions are contained in Schedule 15 to Finance Act 2003 (FA 2003), introduced by s 104. For the purposes of Stamp Duty Land Tax (SDLT), dealings of the partnership are treated as being by or on behalf of the partners and not by the partnership. Under the Limited Partnerships Act 1907, a Limited Liability Partnerships (LLP) must have at least one general partner who manages the business and has full liability for the partnership debts, plus one or more limited partners, who cannot be involved in management but are only liable to the extent of their original capital contributions. Generally, all reliefs and exemptions, including Disadvantaged Area Relief (DAR), apply to partnership transactions together with both group and charities reliefs. Any nomination must be notified to Her Majesty's Revenue and Customs (HMRC) before it comes into effect, before revocation of a nomination comes into effect.
