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Her Majesty's Commissioners of Inland Revenue (Respondents) v. Laird Group plc (Appellants)
(ii) the transaction or transactions have occurred in one or more of the five sets of circumstances mentioned in section 704; and
(iii) in consequence of the transaction or the combined effect of two or more such transactions the taxpayer has obtained or is in a position to obtain a tax advantage.
"(2) 'transaction in securities' includes transactions, of whatever description, relating to securities, and in particular -
(ii) the issuing or securing the issue of, or applying or subscribing for, new securities;
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