(1)The persons referred to in section 819(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.