Provisions exist to counter attempts by pension schemes to invest in taxable property by means of an interest in other ‘vehicles’ which themselves may have interests in taxable property (or indeed, an interest in other persons who have interests in such vehicles, and so on). An interest is held in another person if the pension scheme has an interest in, or power over, that person or has lent that person the funds with which to acquire the interest in the taxable property (FA 2004, Sch. 29A, para. 16(1)–(2)).

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