Commentary

B5.239 Person chargeable on 'artificial' transactions in land—rules prior to 2016

Business tax
Business tax | Commentary

B5.239 Person chargeable on 'artificial' transactions in land—rules prior to 2016

Business tax | Commentary

B5.239 Person chargeable on 'artificial' transactions in land—rules prior to 2016

The provisions in this article were replaced, broadly for disposals on or after 5 July 2016 and for amounts recognised in accounts on or after 8 March 2017, by the provisions relating to the taxation of profits arising from a trade which involves either dealing in or developing UK land, see B5.216A and therefore is retained for reference only.

The gain must be obtained by:

  1.  

    (a)     the person acquiring, holding or developing the land; or

  2.  

    (b)     a person connected with a person within (a); or

  3.  

    (c)     a person who is a party to, or concerned in, an arrangement or scheme which enables a gain to be realised in respect of the land by any indirect method or by a series of transactions1

An arrangement or scheme may consist of any number of transactions if a common purpose can be discerned or there is other sufficient evidence of

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