Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 26

Partnership share attributable to corresponding partner: effective date of transfer before 20 October 2003

Schedule 7 paragraph 26 sets out how to determine a corresponding partner's partnership share when calculating the sum of the lower proportions for transfers out of a partnership, where the chargeable interest was originally transferred into the partnership before 20 October 2003.

• This paragraph applies only where the chargeable interest was originally transferred into the partnership before 20 October 2003, and provides a three-step method for determining each corresponding partner's attributable partnership share.
• The starting point is the partner's actual partnership share on the relevant date — 19 October 2003 if they were already a partner by then, or the date they joined if later — to which qualifying increases are added and any decreases are deducted, with the result floored at zero.
• An increase in partnership share only counts if the instrument effecting the transfer was stamped with ad valorem stamp duty; increases that were not so stamped are ignored.
• The relevant chargeable interest is either the interest that ceases to be partnership property as a result of the transaction, or, where the transaction creates a new chargeable interest, the interest out of which that new interest is created.