Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 12 paragraph 3

Condition B: the transferor's relationship to the partnership

Schedule 12, paragraph 3 sets out Condition B, which concerns the status of the person transferring a chargeable interest to a limited liability partnership at the time of the transfer.

• Condition B focuses on who the transferor is and their connection to the partnership that is becoming or forming the limited liability partnership.
• The transferor must either be a partner in a partnership whose members are exactly the same people who are, or will be, members of the limited liability partnership — with no additional persons involved.
• Alternatively, the transferor may hold the chargeable interest as a nominee or bare trustee on behalf of one or more partners in such a partnership.
• This condition ensures that the transfer is genuinely part of a conversion from a traditional partnership to a limited liability partnership, rather than a means of transferring property to unrelated parties.