Related Commentary  Related HMRC Manuals

153(1)  This section applies where the actual provision is made or imposed by means of a series of transactions which include–

(a)the issuing of a security by a company which is one of the affected persons (“the issuing company”), and

(b)the provision of a guarantee by a company which is the other affected person.

153(2)  Section 147(1)(d) is to be read as requiring account to be taken of all factors, including–

(a)the question whether the guarantee would have been provided at all in the absence of the special relationship,

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