Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 para 22

The sum of the lower proportions in relation to a transaction

Section Schedule 7 paragraph 22 sets out the five-step method for calculating the "sum of the lower proportions" when a chargeable interest is transferred out of a partnership, which determines how much of the transaction may be exempt from land transaction tax.

• The calculation identifies relevant owners (those who held the interest before) and their corresponding partners (those receiving the interest who are connected to the owners).
• Each relevant owner's post-transaction share of the chargeable interest is apportioned among their corresponding partners.
• For each corresponding partner, the lower of two figures is taken: the proportion of the interest attributed to them, or their partnership share — this lower figure is called the "lower proportion".
• All the lower proportions are added together to produce the sum of the lower proportions, which reduces the taxable consideration for the transfer.