Related Commentary  Related HMRC Manuals

1015(1)  Securities of a company are special securities for the purposes of paragraph F in section 1000(1) if they meet any of conditions A to E.

1015(1A)  But hybrid capital instruments (within the meaning of section 475C of CTA 2009) are not special securities by reason of meeting condition E.

1015(2)  Condition A is that the securities are issued as described in paragraph D in section 1000(1) (securities issued otherwise than for new consideration).

1015(3)  Condition B is that–

(a)the securities–

(i)are convertible (directly or indirectly) into shares in the company, or

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