In the straightforward case of an investment-regulated pension scheme acquiring a direct interest in taxable property, the ‘total taxable amount’ in relation to the unauthorised payment is deemed to be an amount equal to the consideration given directly or indirectly plus any fees and other costs incurred in connection with that acquisition (FA 2004, Sch. 29A, para. 32(1)–(3)).

(The total taxable amount is the gross amount which is deemed to arise on particular events, which then may need to be apportioned to the investment-regulated pension scheme to reflect its interest in the taxable property concerned: see ¶382-400).

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