Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 2 paragraph 10

Partial assignments of rights in pre-completion transactions

Schedule 2, paragraph 10 deals with situations where an assignment of rights relates to only part of the property or land covered by the original contract, rather than the whole.

• Where an assignment of rights entitles the new buyer to call for transfer of only part of the subject-matter of the original contract, special rules apply.
• The original contract is treated as if the portion being assigned were a separate, standalone contract in its own right.
• The rules on completion and consideration (set out elsewhere in Schedule 2) apply to that notional separate contract accordingly.
• This ensures the tax treatment correctly reflects the partial nature of the assignment, rather than treating it as though the entire original contract had been assigned.