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Home Forums Patrick Cannon How do you protect against the issue of a discovery assessment? Reply To: How do you protect against the issue of a discovery assessment?

#284
Caroline Smith-Clark
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Thank you, that was my initial thought.

Presumably it could be argued that no “scheme transaction” exists given the lack of mens rea (to use criminal law parlance) of the vendor? Although, could HMRC not just argue that the scheme transaction is the declaring of the dividend immediately upon completion?