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- Heading
- Introduction
- Hearing and evidence
- Findings of fact
- The scheme transactions
- History of the tax dispute
- Relevant law
- Discussion
- The parties’ submissions on the meaning of profits or gains
- Our view on the meaning of profits or gains
- The parties’ submissions on who received the transfer of value
- Our view on who received the transfer of value
- Whether the transfer falls to be taken into account for the purposes of income tax
- Conclusions