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27th March 2008 at 4:33 pm
#283
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My view is that if completion occurs at the same time and there has been no previous substantial performance then section 45(3)(a) regards the shareholder as the purchaser and the completion of the original purchase is disregarded. It follows from this that the first transaction is not notifiable. Of course section 75A might apply to the overall transaction to tax it on the full consideration paid by the original purchaser although this does not necessarily follow.