2 to 1 Transfer of Equity fee calculation

Good morning

We have only recently been hit with some Land Registry refunds and taking of lower than expected fees for 2 to 1 Transfer of Equity applications that we have made where there is no monetary consideration involved.

We have been calculating this by taking the value of the property, minus the amount of the existing/continuing charge and basing the fee on that remaining total. However, when we questioned this with somebody at the Land Registry by e-mail, they advised the following:

'For transfers not on sale, a fee is payable under Scale 2 of the Fee Order on the value of the share (Article 4(2)).
The value of the share is calculated by taking the total value of the land (284,000) and subtracting from it the amount outstanding on any existing/continuing charge (167,000) which gives the value of the equity (117,000)

The value of the equity (117,000) is then divided by the number of shares involved to give the value of the share in the equity, in this instance this would be 58,500 as we can assume that the share percentage is 50% as there is nothing to indicate the property is held other than joint tenants, therefore transferor 1 is transferring their 50% share of the property to the transferee (the remaining proprietor).'

This is what we had been doing for 1 to 2 Transfer of Equity cases as there are 2 transferees to split the share between, but is the above the correct way of determining the fee when there is only 1 transferee remaining? It's only recently that we have been seeing Land Registry refunds on this. We have been doing it our way for years without this issue before, and while it's not the end of the world that we're actually getting charged less for these, we would like to make life a bit easier on our accounts team!

Thank you