»Ê¹ÚÌåÓýapp

(This page was introduced on 15 January 2020)

»Ê¹ÚÌåÓýapp first condition to consider when considering whether Section 75A applies is found in S75A(1)(a) and concerns the identification of V and P.

»Ê¹ÚÌåÓýapp condition is that one person (“Vâ€�) disposes of a chargeable interest and another person (“Pâ€�) acquires either that chargeable interest or a chargeable interest derived from it.

»Ê¹ÚÌåÓýapp identification of V and P is an objective test and one that considers the scheme transactions. HMRC do not have discretion when identifying V and P for the purposes of Section 75A.

»Ê¹ÚÌåÓýappre is additional guidance on identifying P where there are multiple parties who could potentially be P and this can be found at SDLTM09160.