SDLT liability on transfer to a Management Company

[not925]

Gents

We are a three person partnership owning a property just converted into four flats. It has a market value of £350k based on individual flat market rates.

We wish to establish a Flat Management Company and eventually transfer the freehold to same. The indidvidual flats being purchased under a 999 year lease and holding a percentage shareholding in the Management company.

Until that time, we would like shareholding equally distributed between the three partners.

Are we liable to SDLT on this transfer (not selling or changing ownership) & could it qualify for Reconstruction relief if so?

Were we to split the shareholding between TWO of the three partners - would this alter the situation re: SDLT?

Any other method of arranging the Management company that is more advantageous from a taxation liability POV?

Looking forward to your usual swift and accurate advice on this one!

Rgds

Jo