[F15(1)Where PAIF seeding relief has been allowed in respect of a transaction (“the relevant transaction”), and the purchaser ceases to be a property AIF—U.K.
(a)at any time after the effective date of that transaction but within the seeding period,
(b)at any time in the control period (see paragraph 21), or
(c)in pursuance of, or in connection with, arrangements made before the end of the control period,
then, subject to sub-paragraph (2), the relief, or an appropriate proportion of it, is withdrawn, and tax is chargeable in accordance with this paragraph.
(2)Relief is withdrawn only if, at the time when the purchaser ceases to be a property AIF, the purchaser holds—
(a)the chargeable interest that was acquired by the purchaser under the relevant transaction, or
(b)a chargeable interest that is derived from that interest.
(3)The amount chargeable is the amount that would have been chargeable in respect of the relevant transaction but for PAIF seeding relief or, as the case may be, an appropriate proportion of the tax that would have been so chargeable.
(4)In sub-paragraphs (1) and (3) an “appropriate proportion” means an appropriate proportion having regard to the subject-matter of the relevant transaction and what is held by the purchaser at the time it ceases to be a property AIF.]
Textual Amendments
F1Sch. 7A inserted (with effect in accordance with Sch. 16 para. 15 of the amending Act) by Finance Act 2016 (c. 24), Sch. 16 para. 4