Where land which 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. There was 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 transactions. It is understood that HMRC have confirmed that s. 108 will not apply in such a case.

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