An anti-avoidance rule means that CTA09/S550 also applies (so that a company is taxed on income as if it had held the securities) where the company has entered into a ‘relevant arrangement’.
A ‘relevant arrangement’ is one where
•A company sells securities and is entitled or obliged to buy them back (or the company sells securities and another person is entitled or obliged to buy them, or another person sells securities and the company is entitled or obliged to buy them); and
Want to read more?
This content requires a Croner-i Tax and Accounting subscription.