Part 13Tax avoidance

Chapter 1Transactions in securities

Circumstances in which income tax advantages obtained or obtainable

687Deductions from profits obtained following distribution or dealings (circumstance B)

1

This section applies in relation to a person if subsections (2) to (4) apply.

2

The person becomes entitled—

a

in respect of securities held or sold by the person, or

b

in respect of securities formerly held by the person,

to a deduction in calculating profits or gains.

3

The entitlement arises in connection with—

a

the purchase of securities where the purchase is followed by the sale of the same or other securities,

b

the sale of securities where the sale is followed by the purchase of the same or other securities,

c

the distribution, transfer or realisation of assets of a company, or

d

the application of such assets in discharge of liabilities.

4

The entitlement arises because of a fall in the value of the securities resulting from—

a

the payment of a dividend on them, or

b

any other dealing with any assets of a company.

5

Subsection (2)(b) applies whether or not the person has sold the securities.