Land and Buildings Transaction Tax (Scotland) Act 2013 section Sch 11 para 32

Meaning of "appropriate proportion"

Schedule 11 paragraph 32 defines what is meant by an "appropriate proportion" in the context of group relief provisions.

• An "appropriate proportion" is not a fixed percentage but is determined on a case-by-case basis.
• It must be assessed by reference to the subject matter of the relevant land transaction.
• It must also take into account what property or interests are held at the relevant time by the acquiring company.
• Where relevant associated companies exist, their holdings at the relevant time must also be considered alongside those of the acquiring company.