Nature of the relief

A land transaction that transfers a chargeable interest to a limited-liability partnership (LLP) in connection with its incorporation is exempt from charge if the qualifying conditions are met (Sch. 12, para. 1).

Points to note

The relief works by way of ‘exempt from charge’ because the land transaction is otherwise chargeable.

‘Exempt from charge’ is not the same as a transaction being an exempt transaction; exempt transactions are only those as provided under Schedule 2 of the Act.

The incorporation has to be into an LLP and not into a limited company.

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