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25th April 2008 at 12:30 am
#310
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Yes, the some of the guidance states that mere linkage through conveyancing succession will not suffice to make the transactions linked.
However, HMRCs Technical Newsletter 4 states that their view is that a scheme transaction which is a transfer of rights will necessarily be ‘involved in connection with’ both the disposal and acquisition despite the case that V may not know of the subsequent transfer of rights.
Surely they are setting their stall out for a fight in the courts? There doesn’t seem to be much else they can do.