This appeal, in which Patrick Cannon appeared for the taxpayer company, contains a detailed analysis of the scope of the 15% SDLT charge under Schedule 4A FA 2003 and whether there was ‘representative occupation” by a director and also of the sum of the lower proportions calculation in para 20 Schedule 15 FA 2003 and the attribution of control to associates within section 451 CTA 2010 in a purchase by a company from an LLP whose partners were connected with the purchasing company.
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