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HMRC internal manual

VAT Land and Property

Option to tax anti-avoidance - funding and financing: what are funds?

Under paragraph 14(4) the provision of funds includes but is not limited to:

  • a loan
  • guaranteeing a loan
  • share issues, etc
  • the provision of funds to acquire shares or securities, and
  • transferring assets as a result of which either the asset is used for the purposes of raising funds or the funding needed for the development is reduced.