SCHEDULE 12RELIEF FOR INCORPORATION OF LIMITED LIABILITY PARTNERSHIP

Condition B

3

Condition B is that at the relevant time the transferor—

(a)

is a partner in a partnership comprised of all the persons who are, or are to be, members of the limited liability partnership (and no-one else), or

(b)

holds the chargeable interest as nominee or bare trustee for one or more of the partners in such a partnership.