Part 13 U.K.Tax avoidance

Chapter 1U.K.Transactions in securities

Person liable to counteraction of income tax advantagesU.K.

684Person liable to counteraction of income tax advantageU.K.

(1)This section applies to a person in respect of a transaction in securities or two or more such transactions if the person is in a position to obtain or has obtained an income tax advantage—

(a)in circumstances where any of the provisions specified in subsection (2) applies in relation to the person, and

(b)in consequence of—

(i)the transaction, or

(ii)the combined effect of the transactions.

(2)The provisions are—

(3)For the purposes of this Chapter an income tax advantage is treated as obtained or obtainable by a person in consequence of—

(a)a transaction in securities, or

(b)the combined effect of two or more such transactions,

if it is obtained or obtainable by the person in consequence of the combined effect of the transaction or transactions and the liquidation of a company.

(4)This section is subject to—