I act for H and W who each own two mortgaged properties. They have been advised by their FA to transfer the properties into joint ownership as part of a refinancing exercise and the eventual transfer of their buy to let business to a limited company. The bank with which they are refinancing will not agree to each of them making a Declaration of Trust for each property with an indemnity in relation to the mortgage to avoid SDLT surcharge. FA has suggested H and W establish a partnership with each contributing their respective properties (and mortgages) and each retaining their respective interests and 100% SDLT relief would apply. Do any forum members agree?