The increase in the use of partnerships (both onshore and offshore) within corporate structures can give rise to varied stamp duty outcomes across the jurisdictions. In the post-Danvest world this session aimed to highlight the differences between the jurisdictions and the challenges taxpayers face. This session dealt with:
- overview of the treatment partnerships on a State by State basis (transfer duty, partnership provisions and landholder duty)
- characteristics of common types of foreign partnerships and their treatment for stamp duty purposes
- can corporate reconstruction relief apply when partnerships are within the corporate group?
- the difficulties taxpayers face when attempting to restructure a "wholly owned"? group which includes partnerships.