SDLTM09220 - The chargeable consideration: Section 75A (1)(c)

(This page was introduced on 15 January 2020)

The chargeable consideration for the notional transaction is the largest amount or the aggregate amount:

• given by or on behalf of any one person as consideration for any of the scheme transactions, or
• received by or on behalf of V, or a person connected with V, as consideration for any of the scheme transactions.

Section 1122 of the Corporation Tax Act 2010 applies here in determining whether a person is connected with V.

For the purposes of Section 75A, an amount of consideration also includes the money’s worth value of any consideration.

There are a number of other factors to take into account in considering what the chargeable consideration would be for the notional transaction. For further information on incidental transactions see SDLTM09240 onwards and for the supplementary provisions which may affect the consideration for the notional transaction see SDLTM09270 onwards.