Land and Buildings Transaction Tax (Scotland) Act 2013 section 69

Crown application

Section 69 clarifies the extent to which the Land and Buildings Transaction Tax applies to the Crown and to the Sovereign in a personal capacity.

• LBTT applies to the Crown, meaning government departments and other Crown bodies are subject to the tax on land transactions in Scotland.
• However, the Act does not affect Her Majesty in her private capacity — meaning the Sovereign's personal property dealings are exempt from LBTT.
• This distinction between the Crown acting in an official governmental role and the Sovereign acting privately is a long-established principle in UK law.
• In practice, this exemption is narrow and applies only to the Sovereign's personal transactions, not to transactions carried out by government bodies or other parts of the Crown.