Part 4Savings and investment income

Chapter 12Disposals of futures and options involving guaranteed returns

When disposals involve guaranteed returns

559When disposals involve guaranteed returns

1

For the purposes of this Chapter, a disposal of a future or option involves guaranteed returns if conditions A to C are met.

2

Condition A is that the disposal is one of two or more related transactions (see section 566).

3

Condition B is that those transactions are designed to produce a guaranteed return (see subsection (5)).

4

Condition C is that the guaranteed return comprises—

a

the return from the disposal (see section 561), or

b

the return from a number of disposals of futures or options, of which the disposal is one, taken together.

5

For the purposes of this Chapter, two or more related transactions are transactions designed to produce a guaranteed return if, taking them together, it would be reasonable to assume from one or more of the matters specified in subsection (6) that—

a

the main purpose of the transactions is or was the production of a guaranteed return from one or more disposals of futures or options (see section 560), or

b

that is or was one of their main purposes.

6

Those matters are—

a

the likely effect of the transactions,

b

the circumstances in which the transactions are entered into, and

c

the circumstances in which any one of the transactions is entered into.

7

In the case of a transaction which is a disposal, the references in subsection (6) to entering into the transaction are references to making the disposal.