Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 7 paragraph 6

Continuity of partnership despite changes in membership

Schedule 7 paragraph 6 establishes when a partnership retains its identity for Land Transaction Tax purposes, even when its membership changes.

• A partnership is treated as the same partnership even if its membership changes, provided at least one original member remains.
• The key test is whether any person who was a member before the change continues as a member after the change.
• This continuity rule applies for all purposes of the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017.
• If all original members leave and are entirely replaced by new members, the partnership would not be treated as the same partnership.