Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 4

Partnership property treated as held by the partners

Schedule 7 paragraph 4 establishes that, for Land Transaction Tax purposes, partnership property and transactions are treated as belonging to the individual partners rather than to the partnership itself.

• Any chargeable interest (such as land or buildings) held by or on behalf of a partnership is treated as held by the individual partners, not by the partnership as a separate entity.
• Any land transaction carried out for the purposes of a partnership is treated as entered into by or on behalf of the partners individually.
• This "look-through" treatment applies even where the partnership is recognised as a separate legal person or body corporate under the law of the country where it was formed.
• The effect is that LTT always focuses on the partners behind the partnership, ensuring the tax rules apply to the individuals or entities who are partners rather than to the partnership vehicle itself.