Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 14

The sum of the lower proportions in relation to a transaction to which paragraph 13 applies

Schedule 7, paragraph 14 sets out how to calculate the "sum of the lower proportions" when a chargeable interest is transferred into a partnership, which determines the extent to which the transaction may benefit from a reduced tax charge.

• Identify the relevant owners of the chargeable interest before the transfer, then identify which partners in the partnership correspond to those owners (e.g. the same person, or a connected company).
• For each relevant owner, determine the proportion of the chargeable interest they held before the transfer and apportion that proportion among their corresponding partners.
• For each corresponding partner, compare the proportion of the interest attributed to them with their actual partnership share immediately after the transaction, and take the lower of the two figures.
• Add together all the lower proportions for every corresponding partner — this total is the "sum of the lower proportions," which reduces the chargeable consideration for the transfer.