Where land that has been held by two or more persons is partitioned or divided, the share of the land held by the purchaser immediately before the partition does not form part of the chargeable consideration (Sch. 4, para. 6).

There has been some concern that where there is a partition between connected persons, the linked-transaction rule in s. 108 would apply to amalgamate both sides of the transaction. It is understood that HMRC has confirmed that s. 108 would not apply in such a case.

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