Part 13Tax avoidance
Chapter 1Transactions in securities
F1Person liable to counteraction of income tax advantages
684Person liable to counteraction of income tax advantage
1
This section applies to a person F3(“the party”) where—
a
the person is a party to a transaction in securities or two or more transactions in securities (see subsection (2)),
b
the circumstances are covered by section 685 and not excluded by section 686,
c
the main purpose, or one of the main purposes, of F4... the transaction in securities, or any of the transactions in securities, is to obtain an income tax advantage, and
d
F5the party or any other person obtains an income tax advantage in consequence of the transaction or the combined effect of the transactions.
2
In this Chapter “transaction in securities” means a transaction, of whatever description, relating to securities, and includes in particular—
a
the purchase, sale or exchange of securities,
b
issuing or securing the issue of new securities,
c
applying or subscribing for new securities, F6...
d
altering or securing the alteration of the rights attached to securities.
F2e
a repayment of share capital or share premium, and
f
a distribution in respect of securities in a winding up.
3
Section 687 defines “income tax advantage”.
F74
This section is subject to no-counteraction notices issued under section 698A.
Ss. 682-687 and cross-headings substituted (8.4.2010 with effect in accordance with Sch. 12 para. 15(1) of the amending Act) for s. 682-694 and cross-headings by Finance Act 2010 (c. 13), Sch. 12 para. 2