Part 13Tax avoidance

Chapter 1Transactions in securities

Circumstances in which income tax advantages obtained or obtainable

692Abnormal dividends: general

1

An amount received by way of dividend is treated as abnormal for the purposes of this Chapter if the appropriate authority is satisfied—

a

in any case that the excessive return condition is met (see section 693), or

b

in the case of a dividend at a fixed rate, that the excessive accrual condition is met (see section 694).

2

In subsection (1) “the appropriate authority” means whichever of the following is determining the question whether the amount is abnormal for the purposes of this Chapter—

a

an officer of Revenue and Customs,

b

the Commissioners for Her Majesty's Revenue and Customs,

c

the Special Commissioners, or

d

the tribunal appointed under section 704.