Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section 51

Connected persons

Schedule 7, paragraph 51 sets out how the concept of "connected persons" applies to partnership land transactions for the purposes of Land Transaction Tax.

• The definition of "connected persons" used throughout the partnerships schedule is taken from section 1122 of the Corporation Tax Act 2010.
• However, the rule that partners in the same partnership are automatically connected with each other is switched off for these purposes.
• For certain calculations relating to transfers of property into or out of a partnership (the "relevant owner" and "corresponding partner" provisions), additional modifications remove the rules treating trustees as connected with a settlement.
• These modifications ensure that the connected persons test operates appropriately in the context of partnership property transactions, preventing unintended consequences.