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1st December 2010 at 8:57 am
#495
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The reality is that most advisors are of the view that the scheme is caught by Section 75A. Even before PBR 2006 it was vulnerable under Ramsay given that the structure amounted to the insertion of company which lasted a brief time and for no other purpose than the avoidance of tax.
The brave will rely on the arguing that the first transaction is not a scheme transaction for the purposes of Section 75A if the seller is not aware of the subsequent transaction.
Best wishes
Nick