SCHEDULE 7PARTNERSHIPS

PART 4TRANSACTIONS INVOLVING TRANSFERS TO A PARTNERSHIP

Relevant owner

15

(1)

For the purposes of paragraph 14 (see Step 1), a person is a relevant owner if—

(a)

immediately before the transaction, the person was entitled to a proportion of the chargeable interest, and

(b)

immediately after the transaction, the person is a partner or is connected with a partner.

(2)

For the purposes of paragraph 14 and this paragraph, persons who are entitled to a chargeable interest as beneficial joint tenants are taken to be entitled to the chargeable interest as beneficial tenants in common in equal shares.