Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 27

Partnership share attributable to a partner: transfers to partnership on or after 20 October 2003

Schedule 7, paragraph 27 explains how to calculate a partner's attributable partnership share when working out the "sum of the lower proportions" for transfers out of a partnership, where the chargeable interest was originally transferred into the partnership on or after 20 October 2003.

• If no stamp duty, land transaction tax or stamp duty land tax was paid on the original transfer of the interest into the partnership, the partner's attributable share is treated as zero.
• If the relevant tax was paid, a three-step calculation determines the attributable share: start with the partner's actual share at the relevant date, add qualifying increases, then deduct any decreases occurring before the current transaction.
• Increases in partnership share only count if the appropriate tax was paid on the transfer that caused the increase — stamp duty for transfers on or before 22 July 2004, or LTT/SDLT for transfers after that date.
• If the calculation produces a negative figure, or the partner had already left the partnership before the interest was transferred in, the attributable share is zero.