Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 16

Corresponding partners

Schedule 7, paragraph 16 defines who counts as a "corresponding partner" in relation to a relevant owner when calculating the sum of the lower proportions for a transfer of a chargeable interest to a partnership.

• A corresponding partner is someone who, immediately after the transfer to the partnership, is both a partner and either the relevant owner themselves or an individual connected with the relevant owner.
• This definition is used in the Step 2 calculation under paragraph 14, which determines the sum of the lower proportions — a key figure in working out how much land transaction tax is due on the transfer.
• A company that holds property as a trustee can be treated as if it were an individual connected with the relevant owner, but only where the connection arises solely through the trustee relationship rules in section 1122(6) of the Corporation Tax Act 2010 (disregarding certain other connecting provisions in that subsection).
• The effect of this rule is to ensure that where a relevant owner transfers a chargeable interest into a partnership in which they or connected persons are partners, the tax charge is reduced proportionally to reflect the continuing economic interest of those persons.