Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 11 paragraph 3

Treatment of bond-holder and bond-issuer interests

Schedule 11 paragraph 3 clarifies how the parties to an alternative finance investment bond are treated for land transaction tax purposes, ensuring that the bond structure does not inadvertently create property interests or trust obligations.

• A bond-holder under an alternative finance investment bond is not treated as having an interest in the underlying bond assets.
• A bond-issuer under such a bond is not treated as a trustee of the bond assets.
• This prevents the bond-holder from being regarded as owning a share of the land or property held within the bond arrangement.
• This ensures the bond-issuer is not subject to trustee obligations in relation to the bond assets for land transaction tax purposes.