Land and Buildings Transaction Tax (Scotland) Act 2013 section 39

If two or more transactions effected at the same time

Section 39 deals with how to identify the relevant seller when two or more simultaneous transactions qualify as the earliest previous transactions in the chain of successive transactions that can trigger withdrawal of group relief.

• This provision addresses a specific scenario where multiple transactions occur at exactly the same time within a chain of related transactions
• Where two or more simultaneous transactions each qualify as the earliest previous transaction under the successive transactions rules, all of them are treated as earliest previous transactions
• Instead of referring to a single seller in relation to the earliest previous transaction, the rules refer collectively to the sellers involved in all of those simultaneous earliest previous transactions
• This ensures the withdrawal of group relief rules work correctly even when the starting point of the transaction chain involves multiple simultaneous deals rather than a single one