Part 13Tax avoidance

Chapter 1Transactions in securities

F1Person liable to counteraction of income tax advantages

Annotations:
Amendments (Textual)
F1

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

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.