Part 13Tax avoidance

Chapter 1Transactions in securities

Person liable to counteraction of income tax advantages

685Exception where no tax avoidance object shown

1

Section 684 does not apply to a person in respect of a transaction in securities or two or more such transactions if the person shows that the transaction or transactions meet conditions A and B.

2

Condition A is that the transaction or transactions are effected—

a

for genuine commercial reasons, or

b

in the ordinary course of making or managing investments.

3

Condition B is that enabling income tax advantages to be obtained is not the main object or one of the main objects of the transaction or, as the case may be, any of the transactions.