Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 17

Proportion of chargeable interest attributable to a corresponding partner

Schedule 7 paragraph 17 explains how to work out the proportion of a chargeable interest attributable to a corresponding partner for the purposes of the Step 4 calculation when property is transferred to a partnership.

• This paragraph supports the Step 4 calculation in paragraph 14 by defining how much of the chargeable interest is attributable to each corresponding partner.
• Where a partner corresponds to only one previous owner, their attributable proportion is simply the amount apportioned to them at Step 3 in respect of that owner.
• Where a partner corresponds to more than one previous owner, their attributable proportion is the total of all the amounts apportioned to them at Step 3 in respect of each of those owners.
• The distinction matters because a partner who was connected to multiple previous owners aggregates all relevant apportioned shares, which increases the amount excluded from the chargeable consideration calculation.