ITEPA 2003 – section 554Z5

Besides the conditions listed in the previous paragraphs, the section contains other provisions which need to be considered.

Where the earlier tax liability arose as a result of a relevant step within Part 7A on sum or asset Q, the sum or asset which is the subject of the later relevant step (P), is treated as overlapping with any other sum or asset, provided that these have been treated as overlapping with the original sum or asset Q.

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