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.



Family relationship

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