(1)For the purposes of this Part, account is to be taken of any method, however indirect, by which—
(a)any property or right is transferred or transmitted, or
(b)the value of any property or right is enhanced or diminished.
(2)Accordingly—
(a)the occasion of the transfer or transmission of any property or right however indirect, and
(b)the occasion when the value of any property or right is enhanced,
may be an occasion when tax is charged as a result of this Part.
(3)Subsections (1) and (2) apply in particular—
(a)to sales, contracts and other transactions made otherwise than for full consideration or for more than full consideration,
(b)to any method by which any property or right, or the control of any property or right, is transferred or transmitted by assigning—
(i)share capital or other rights in a company,
(ii)rights in a partnership, or
(iii)an interest in settled property,
(c)to the creation of an option affecting the disposition of any property or right and the giving of consideration for granting it,
(d)to the creation of a requirement for consent affecting such a disposition and the giving of consideration for granting it,
(e)to the creation of an embargo affecting such a disposition and the giving of consideration for releasing it, and
(f)to the disposal of any property or right on the winding up, dissolution or termination of a company, partnership or trust.
(1)This section applies if it is necessary to determine the extent to which the value of any property or right is derived from any other property or right for the purposes of this Part.
(2)Value may be traced through any number of companies, partnerships and trusts.
(3)The property held by a company, partnership or trust must be attributed to the shareholders, partners or beneficiaries at each stage in such manner as is appropriate in the circumstances.
(1)For the purposes of this Part references to other persons are to be read in accordance with subsections (2) to (4).
(2)A partnership or partners in a partnership may be regarded as a person or persons distinct from the individuals or other persons who are for the time being partners.
(3)The trustees of settled property may be regarded as persons distinct from the individuals or other persons who are for the time being the trustees.
(4)Personal representatives may be regarded as persons distinct from the individuals or other persons who are for the time being personal representatives.
(1)All such valuations are to be made as are appropriate to give effect to this Part.
(2)For the purposes of this Part, any expenditure, receipt, consideration or other amount may be apportioned by such method as is just and reasonable in the circumstances.