Related Commentary  Related CasesRelated HMRC Manuals

10(1)  A disposition is not a transfer of value if it is shown that it was not intended, and was not made in a transaction intended, to confer any gratuitous benefit on any person and either–

(a)that it was made in a transaction at arm’s length between persons not connected with each other, or

(b)that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.

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