Part 13Tax avoidance

Chapter 3Transactions in land

Charge on gains from transactions in land

757Person obtaining gain

1

The persons referred to in section 756(1)(d) are—

a

the person acquiring, holding or developing the land,

b

a person connected with a person within paragraph (a), and

c

a person who is a party to, or concerned in, an arrangement or scheme within subsection (2).

2

An arrangement or scheme is within this subsection if—

a

it is effected as respects all or part of the land, and

b

it enables a gain to be realised—

i

by any indirect method, or

ii

by any series of transactions.

3

For the purposes of this section any number of transactions may be regarded as constituting a single arrangement or scheme if—

a

a common purpose can be discerned in them, or

b

there is other sufficient evidence of a common purpose.