The sale, exchange, gift or assignment of an asset, or any other arrangement which equates in substance to a transfer, will constitute a transfer for the purposes of CTA 2010, Pt. 16, Ch. 1 (CTA 2010, s. 757(3)(a)). The following guidance was provided in the 2007 consultation document (see ¶811-000) and was quoted in the Explanatory Notes accompanying the Finance Act 2009:

‘This might include transactions involving options, total return swaps, etc. It would not however cover transactions which amount in form to a transfer but in substance to, say, the giving of security such as in a repo.’

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