(1)This section applies in relation to a company (“the section 733 company”) if subsections (2) to (4) apply.
(2)The section 733 company receives consideration in connection with—
(a)the distribution, transfer or realisation of assets of a relevant company (see section 739), or
(b)the application of such assets in discharge of liabilities.
(3)The consideration—
(a)is or represents the value of—
(i)assets which are available for distribution by way of dividend by the relevant company, or
(ii)assets which would have been so available apart from anything done by the relevant company,
(b)is received in respect of future receipts of the relevant company, or
(c)is or represents the value of trading stock of the relevant company.
(4)The section 733 company so receives the consideration that it does not pay or bear corporation tax on income in respect of it (apart from this Part).
(5)The assets mentioned in subsection (3) do not include assets which are shown to represent a return of sums paid by subscribers on the issue of securities, despite the fact that under the law of the country in which the relevant company is incorporated assets of that description are available for distribution by way of dividend.
(6)In this section references to the receipt of consideration include references to the receipt of any money or money's worth.