Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 17 paragraph 1

Overview of reconstruction relief and acquisition relief

Schedule 17, paragraph 1 introduces the schedule dealing with two types of land transaction tax relief: reconstruction relief and acquisition relief, and sets out how the schedule is organised.

• The schedule covers two distinct reliefs: reconstruction relief (for schemes of reconstruction) and acquisition relief (for company acquisitions of undertakings).
• Reconstruction relief applies where a land transaction takes place as part of a formal scheme of reconstruction — for example, when a company is reorganised and land is transferred as part of that process.
• Acquisition relief applies where one company acquires the whole or part of the undertaking of another company and a land transaction is involved, reducing the amount of tax chargeable.
• The schedule also deals with circumstances in which either relief can be withdrawn, and with the recovery of any unpaid tax from certain persons following such withdrawal.