Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 2 paragraph 8

Notional land transactions arising from assignments of rights

Schedule 2 paragraph 8 sets out how notional land transactions are created when an assignment of rights leads to the original contract being completed or substantially performed, and how the chargeable consideration for those notional transactions is calculated.

• When an assignment of rights results in completion or substantial performance of the original contract, the law treats the original buyer as the buyer in a separate notional land transaction occurring on the same effective date as the transferee's transaction.
• If a chain of successive assignments of rights preceded the final implemented assignment, an additional notional land transaction is created for each link in the chain (other than the first), with each earlier transferor treated as the buyer in their respective notional transaction.
• The chargeable consideration for the first notional land transaction is the sum of two amounts (A + B), while each additional notional transaction in a chain uses the sum of three amounts (A + B + C).
• A represents consideration paid under the original contract by the transferee (and any subsequent transferees in the chain, plus connected persons); B represents other consideration paid under the original contract by the notional buyer or connected persons; and C represents consideration paid by the notional buyer (or connected persons) for the preceding assignment of rights itself.