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Schedule 2A Transactions entered into before completion of contractF1

  1. Pre-completion transactions
  2. Other key expressions
  3. Tax not charged on transferee by reason of the pre-completion transaction
  4. Assignments of rights: application of rules about completion and consideration
  5. Assignment of rights: transferor treated as making separate acquisition
  6. Paragraph 5: effect of rescission etc following substantial performance
  7. Assignment of rights relating to part only of subject-matter of original contract
  8. Assignment of rights: references to “the vendor”
  9. Free-standing transfers: consideration and substantial performance
  10. Meaning of “the vendor”: cases involving free-standing transfers
  11. Paragraph 10: “the first appropriate transaction” and “the original contract”
  12. Minimum consideration rule
  13. The first minimum amount
  14. The second minimum amount
  15. Relief for transferor: assignment of rights
  16. Relief for original purchaser: qualifying subsales
  17. Application of paragraph 16 to successive subsales
  18. Tax avoidance arrangements
  19. Exclusion of transactions from duty to make returns etc
  20. Connected persons
  21. 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