Para20 states that:

The sum of the lower proportions in relation to a transaction to which Para18 applies is determined as follows:

Step One

Identify the relevant owner or owners.

A person is a relevant owner if

(1)immediately after the transaction, he is entitled to a proportion of the chargeable interest, and

(2)immediately before the transaction, he was a partner or connected with a partner.

Step Two

For each relevant owner, identify the corresponding partner or partners.

A person is a corresponding partner in relation to a relevant owner if, immediately before the transaction-

(1)he was a partner, and

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