Transactions are ‘linked’ if they form part of a ‘single scheme, arrangement or series of transactions between the same vendor and purchaser or, in either case, persons connected with them’ (s. 108(1)).

The legislation uses the definition of ‘connected persons’ found in CTA 2010, ss. 1122.

Exchanges of interests within s. 47(1) are, though, not linked transactions. For the treatment of exchanges, see ¶40-400ff.

See also Aspden v Hildesley [1982] BTC 69;

Connected persons

An illustrative table is set out below.

Relationship

Connection

Family relationship

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.