Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 24

Corresponding partners in relation to relevant owners

Schedule 7 paragraph 24 defines who counts as a "corresponding partner" in relation to a relevant owner when calculating the sum of the lower proportions for transfers of chargeable interests out of a partnership.

• A corresponding partner must have been a partner in the partnership immediately before the transfer transaction took place.
• That partner must either be the relevant owner themselves or be an individual who is connected with the relevant owner.
• A company acting as a trustee can be treated as if it were an individual connected with the relevant owner, but only where the connection arises through the trustee relationship under a specific provision of the Corporation Tax Act 2010.
• This definition feeds into Step 2 of the calculation in paragraph 22, which determines how much of the market value of the transferred interest is subject to land transaction tax.