Schedule 2 paragraph 54 FA 2011

Suppose that a relevant third person (P) takes a relevant step within Section 554C(1)(d) (see EIM45070) between 9 December 2010 and 5 April 2011 (inclusive). This step is labelled ‘the early step’.

Anti-forestalling rules may apply. Note that, for the purposes of these rules, the application of Section 554C(1)(d) is narrowed down. Some transactions that would come within Section 554C(1)(d) will fall outside the narrower set of circumstances to which these rules apply.


In order for the anti-forestalling rules to apply, six conditions must be met. These conditions are bulleted below.

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