Land and Buildings Transaction Tax (Scotland) Act 2013 section Schedule 5 paragraph 15

"Attributable" means attributable on a just and reasonable basis

Schedule 5, paragraph 15 defines how amounts should be attributed when apportioning consideration or other values for LBTT purposes.

  • Where LBTT rules require an amount to be "attributable" to something, it must be apportioned on a just and reasonable basis.
  • This applies whenever consideration or value needs to be split between different elements of a transaction.
  • The apportionment must be both fair ("just") and sensible ("reasonable") in the circumstances.
  • This provides a general rule of interpretation that applies across the whole of Schedule 5 and wherever the term "attributable" is used in the LBTT legislation.

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