Income Tax (Trading and Other Income) Act 2005

437Transactions which are disposalsU.K.
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(1)References in this Chapter to the disposal of a deeply discounted security are—

(a)to its redemption,

(b)to its transfer by sale, exchange, gift or otherwise, including a transfer treated as made by subsection (3), and

(c)so far as not covered by paragraph (a) or (b), to its conversion under its terms into shares in a company or other securities (including other deeply discounted securities).

(2)The person treated as making a disposal is—

(a)in the case of a disposal within subsection (1)(a), the person entitled as the security's holder to any payment on the disposal,

(b)in the case of a disposal within subsection (1)(b), the transferor, and

(c)in the case of a disposal within subsection (1)(c), the person who would be entitled as the security's holder to any payment on the disposal, if such a payment were made.

(3)A person who dies while entitled to a deeply discounted security is treated as transferring it immediately before death to the personal representatives.

(4)In the case of strips, further provision about occasions counting as disposals is made by section 445(2) and (6)(a).

[F1(5)In the case of interest-bearing corporate securities, further provision about occasions counting as disposals is made by section 452F(2)(a).

(6)In the case of corporate strips, further provision about occasions counting as disposals is made by section 452F(2)(a) and (3)(a).]

Textual Amendments

F1S. 437(5)(6) inserted (retrospectively) by Finance (No. 2) Act 2005 (c. 22), s. 39, Sch. 7 para. 25(3)(10)