What happens when GP practices merge

What happens with stamp duty land tax (SDLT) when two GP partnerships with properties ‘merge’ and what is a partnership merger?

This was the question in Taxation’s readers’ forum query 20 272 ‘SDLT on freehold owned by partnerships’ (tinyurl.com/fhnzhj4z) (24 February 2024). The conclusions – as is often the case with readers’ forum complex issues – had some uncertainty. John Shallcross and I have since been discussing this intriguing question and we share our thoughts with Taxation readers.

Optimist’s original question was that: ‘each partnership owns a freehold property (both properties are recognised in the respective partnership accounts) with mortgages attached which are held by each equity partner in accordance with their profit sharing ratios. Due to the net equity (ie market value less mortgage) being larger in Partnership 1 the partners of Partnership 2 are being asked to contribute the difference to the...