Corporation Tax Act 2010

1114“In respect of securities”U.K.

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(1)In this Part “in respect of securities of the company”, in relation to a company which is a member of a 90% group, means in respect of securities of—

(a)that company, or

(b)any other company in the group.

(2)Nothing in subsection (1) requires a company to be treated as making a distribution to any company which is in the same group and is UK resident.

(3)For the purposes of this Part, except where the context otherwise requires—

(a)interest paid by a company on money advanced without the issue of a security for the advance, or

(b)other consideration given by a company for the use of money so advanced,

is treated as if paid, or given, in respect of a security issued for the advance by the company.

(4)For the purposes of this Part a thing is regarded as done in respect of a security if it is done to a person—

(a)as the holder of the security, or

(b)as the person who held the security at a particular time.

(5)For the purposes of this Part a thing is also regarded as done in respect of a security if it is done in pursuance of a right granted, or an offer made, in respect of a security.

(6)In this section “90% group” means a company and all its 90% subsidiaries.