51(1)Section 409(2) of CTA 2009 (postponement until redemption of debits for close companies’ deeply discounted securities) does not apply to a qualifying debit.
(2)For the purposes of this paragraph, a debit is “qualifying” if—
(a)it is a debit in respect of a deeply discounted security of the QAHC that relates to the amount of the discount,
(b)the QAHC is party to the security for the purposes of its QAHC ring fence business, and
(c)the discount to which the debit relates is referable to an accounting period during which the QAHC is a QAHC.
(3)Where a QAHC is party to a deeply discounted security partly for the purposes of its QAHC ring fence business and partly for another purpose, sub-paragraph (1) applies only to the proportion of the qualifying debit that is attributable to the QAHC ring fence business (apportioned on a just and reasonable basis).
(4)In this paragraph—
“debit” is to be construed in accordance with Part 5 of CTA 2009;
“deeply discounted security” has the meaning it has in Chapter 8 of Part 4 of ITTOIA 2005 (profits from deeply discounted securities) (see section 430 of that Act);
“the discount” has the meaning given by section 406(3) of CTA 2009.