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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?

#285
Caroline Smith-Clark
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The argument for the taxpayer is that the completion of original purchase is disregarded for SDLT by section 45(3) and therefore is not a ‘scheme transaction’ and so cannot be aggregated with the dividend in specie to form a notional transaction under section 75A.