SCHEDULE 7PARTNERSHIPS

PART 5TRANSACTIONS INVOLVING TRANSFERS FROM A PARTNERSHIP

Relevant owner

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1

For the purposes of paragraph 22 (see Step 1), a person is a relevant owner if—

a

immediately after the transaction, that person is entitled to a proportion of the chargeable interest, and

b

immediately before the transaction, that person was a partner or connected with a partner.

2

For the purposes of paragraph 22 and this paragraph, persons who are entitled to a chargeable interest as beneficial joint tenants are to be taken to be entitled to the chargeable interest as beneficial tenants in common in equal shares.