Paragraph 13 F1

Where F2co-ownership scheme seeding relief has been allowed in respect of a transaction (“the relevant transaction”), and the purchaser ceases to be a co-ownership F3... contractual scheme—

then, subject to sub-paragraph (2), the relief, or an appropriate proportion of it, is withdrawn, and tax is chargeable in accordance with this paragraph.

Relief is withdrawn only if, at the time when the purchaser ceases to be a co-ownership F4... contractual scheme, the purchaser holds—

The amount chargeable is the amount that would have been chargeable in respect of the relevant transaction but for F5co-ownership scheme seeding relief or, as the case may be, an appropriate proportion of the tax that would have been so chargeable.

In sub-paragraphs (1) and (3) an “appropriate proportion” means an appropriate proportion having regard to the subject-matter of the relevant transaction and what is held by the purchaser at the time it ceases to be a co-ownership F6... contractual scheme.