Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 15

Definition of a relevant owner for partnership transfers

Schedule 7 paragraph 15 defines who counts as a "relevant owner" when land or property is transferred into a partnership, which is essential for calculating the proportion of the market value that is chargeable to Land Transaction Tax.

• A relevant owner is someone who held a share in the property immediately before the transfer and who, immediately after the transfer, is either a partner or connected with a partner.
• Both conditions must be met: prior ownership of a proportion of the chargeable interest and a post-transaction connection to the partnership.
• Where owners held the property as beneficial joint tenants, they are treated as if they held it as tenants in common in equal shares, so each is regarded as owning an equal proportion.
• This definition feeds directly into the calculation under paragraph 14, where the sum of the lower proportions for each relevant owner determines the chargeable consideration.