SCHEDULE 11
Early redemption: special rules
F119A
(1)
Sub-paragraph (2) below applies where—
(a)
a security is issued on or after 13th November 1991,
(b)
it would be a deep gain security apart from paragraph 1(3B) or (3E) above,
(c)
it is redeemed before maturity, and
(d)
immediately before redemption it was held by a person connected with the person who issued it.
(2)
As regards the redemption, paragraphs 5 to 19 above shall have effect as if—
(a)
the security were a deep gain security, and
(b)
it had been acquired as such (whatever the time it was acquired).
(3)
Sub-paragraph (4) below applies where—
(a)
the conditions set out in sub-paragraph (1)(a) to (c) above are fulfilled,
(b)
the security was transferred in the period ending with redemption and beginning with the day falling one year before the day of redemption, and
(c)
the transfer was by a person connected with the person who issued the security.
(4)
As regards the transfer, paragraphs 5 to 19 above shall have effect as if—
(a)
the security were a deep gain security, and
(b)
it had been acquired as such (whatever the time it was acquired).
(5)
Section 839 of the Taxes Act 1988 (connected persons) shall apply for the purposes of this paragraph.