Schedule 2A Transactions entered into before completion of contractF1
- Pre-completion transactions
- Other key expressions
- Tax not charged on transferee by reason of the pre-completion transaction
- Assignments of rights: application of rules about completion and consideration
- Assignment of rights: transferor treated as making separate acquisition
- Paragraph 5: effect of rescission etc following substantial performance
- Assignment of rights relating to part only of subject-matter of original contract
- Assignment of rights: references to “the vendor”
- Free-standing transfers: consideration and substantial performance
- Meaning of “the vendor”: cases involving free-standing transfers
- Paragraph 10: “the first appropriate transaction” and “the original contract”
- Minimum consideration rule
- The first minimum amount
- The second minimum amount
- Relief for transferor: assignment of rights
- Relief for original purchaser: qualifying subsales
- Application of paragraph 16 to successive subsales
- Tax avoidance arrangements
- Exclusion of transactions from duty to make returns etc
- Connected persons
- Interpretation of Schedule
Annotations
Textual amendments
- F1
Sch. 2A inserted (with effect in accordance with Sch. 39 para. 11 of the amending Act) by Finance Act 2013 (c. 29), Sch. 39 para. 3