Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 11

Joint and several liability of responsible partners

Schedule 7 paragraph 11 sets out that the responsible partners in a partnership are jointly and severally liable for tax, recovery of excessive repayments, penalties, and related late payment interest, but limits the recovery of amounts from partners who joined the partnership after the relevant event.

• Where responsible partners owe land transaction tax, amounts due from excessive repayments, or penalties (including late payment interest on any of these), each partner is jointly and severally liable for the full amount.
• A person who became a responsible partner only after the effective date of the transaction cannot be pursued for tax or excessive repayment amounts.
• A person who became a partner only after the relevant time cannot be pursued for penalties — the relevant time being the start of the day to which a daily penalty relates, or the time the act or omission giving rise to any other penalty occurred.
• Late payment interest in this context means interest charged under Part 6 of the Tax Collection and Management (Wales) Act 2016.