holds himself out at all normal times in compliance with the rules of the Stock Exchange as willing to buy and sell securities of the kind concerned at a price specified by him; and

is recognised as doing so by the Council of the Stock Exchange.

subsections (2), (3) and (6)(a) above shall have effect as if references to the Stock Exchange were to any recognised investment exchange (within the meaning of the F55Financial Services and Markets Act 2000) or to any of those exchanges specified in the regulations; and

subsection (6)(b) shall have effect as if the reference to the Council of the Stock Exchange were to the investment exchange concerned.

shall be F68treated as the income of the owner or, in a case where the owner is not the beneficial owner of the F66shares and some other person (“a beneficiary”) is beneficially entitled to the income arising from the F66shares, the income of the beneficiary, and

shall be F69treated as the income of the owner or beneficiary for that chargeable period, F70. . .

F70. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

the F66shares are of such a character that the F67distribution payable in respect thereof may be paid without deduction of income tax, and

the owner or beneficiary does not show that the proceeds of any sale or other realisation of the right to receive the F67distribution which is deemed to be his income by virtue of this section have been charged to F61income tax under Chapter 13 of Part 4 of ITTOIA 2005 (sales of foreign dividend coupons),

any interest on securities transferred by the lender under a stock lending arrangement is paid, as a consequence of the arrangement, to a person other than the lender; and

no provision is made for securing that the lender receives payments representative of that interest.

the borrower were required under the stock lending arrangement to pay the lender an amount representative of the interest mentioned in subsection (1)(a) above;

a payment were made by the borrower in discharge of that requirement; and

that payment were made on the same date as the payment of the interest of which it is representative.

to any deduction in computing profits or gains for the purposes of F88. . . corporation tax, or

to any deduction against F89. . . total profits,

the borrower under a stock lending arrangement is treated under section 736B(2) as paying under that arrangement an amount representative of interest on any securities (“the relevant securities”),

an amount of money (“cash collateral”) is payable to or for the benefit of the lender for the purpose of securing the discharge of the requirement to transfer the relevant securities back to the lender,

the stock lending arrangement is designed to produce a return to the borrower which equates, in substance, to the return on an investment of money at interest, and

the main purpose, or one of the main purposes, of the stock lending arrangement is the obtaining of a tax advantage.

the F92Corporation Tax Acts are to apply as if the borrower receives an amount of interest payable in respect of the cash collateral, and

the amount of the interest is calculated in accordance with the following provisions of this section (see, in particular, subsections (3) to (7)).

beginning with the date on which the lender transfers the relevant securities to the borrower, and

ending with the return date.

in any case where the amount of the cash collateral varies at any time on or before the return date, the highest amount of the cash collateral at any time on or before the return date, and

in any other case, the amount of the cash collateral as at the return date.

the interest which the borrower is treated as receiving is treated for the purposes of F95Part 5 of CTA 2009 (loan relationships) as payable to it on a money debt,

that money debt is treated for those purposes as a relationship to which F96Chapter 2 of Part 6 of that Act applies (relevant non-lending relationships), and

the credits to be brought into account for those purposes in respect of the interest must be determined using an amortised cost basis of accounting.

any reference to the transfer of securities back has the same meaning as in section 263B of the 1992 Act (see, in particular, sections 263B(5) and 263C(1) of that Act), but

if it becomes apparent that the borrower will not comply with the requirement to transfer any securities back, the borrower is treated as if he transfers them back on the date on which it becomes so apparent.

whether the cash collateral is payable by the borrower or by any other person,

whether the cash collateral is payable under the stock lending arrangement or under any other arrangement,

whether collateral in another form is also provided in connection with the stock lending arrangement.

for provision treating certain arrangements as stock lending arrangements for the purposes of this section, and

for provision treating certain amounts as cash collateral for those purposes.

a person (“the lender”) transfers securities to another person (“the borrower”), and

a requirement is imposed on a person to transfer any or all of the securities, or any other property, back to the lender or any other person,

any money which is payable for a relevant purpose, plus

any other property which is transferable for a relevant purpose.

the lender under the stock lending arrangement or quasi-stock lending arrangement, or

a person connected with that lender,

quasi-cash collateral is treated as if it were cash collateral, and

the amount of the quasi-cash collateral in relation to the stock lending arrangement or quasi-stock lending arrangement is taken to be the amount of the cash collateral.

section 736C applies in relation to a quasi-stock lending arrangement, and

the person for whom the tax advantage was designed to be obtained is a person (“the other person”) other than the borrower under that arrangement,

any reference in that section to cash collateral being payable to or for the benefit of the lender includes its being payable to or for the benefit of a person connected with the lender,

the reference in subsection (1)(c) of that section to a return to the borrower includes a return to any other person, and

any reference in that section to the transfer back of the relevant securities by the borrower to the lender includes the transfer back of any or all of the securities, or any other property, by any person to the lender or any other person.