Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 Schedule 8 paragraph 4

Where persons acquire a chargeable interest or an interest in a partnership as trustees of a settlement

Schedule 8 paragraph 4 establishes that when trustees of a settlement acquire a chargeable interest or an interest in a partnership, they are treated as purchasers of the entire interest, including the beneficial interest.

  • When trustees of a settlement acquire a chargeable interest or partnership interest, they are treated as buyers of the whole interest
  • This treatment applies for all purposes of the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017
  • The trustees' buyer status specifically includes the beneficial interest in the property or partnership, not just the legal title
  • This ensures that the full acquisition is brought within the charge to land transaction tax, preventing any argument that only the legal interest was acquired

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