Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 25

Proportion of chargeable interest attributable to a corresponding partner

Schedule 7 paragraph 25 explains how to work out the proportion of a chargeable interest attributable to a corresponding partner when calculating the sum of the lower proportions (Step 4) for transfers of property out of a partnership.

• This paragraph supports the calculation at Step 4 of the sum of the lower proportions under paragraph 22, which determines how much of a partnership property transfer may be exempt from LTT.
• Where a partner corresponds to only one relevant owner (i.e. they are the same person or connected to only one of the previous owners), their attributable proportion is simply the amount apportioned to them at Step 3 in respect of that single owner.
• Where a partner corresponds to more than one relevant owner, their attributable proportion is the total of all the amounts apportioned to them at Step 3 in respect of each of those owners added together.
• The effect is to gather up all the ownership proportions linked to a particular corresponding partner so that a single figure can be used at Step 4 of the calculation.