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Income Tax Act 2007

Section 621: Transferors and transferees

1817.This section defines who is a “transferor” or “transferee” for the purposes of the Chapter. It is based on section 710(13) and section 717(8) of ICTA.

1818.Subsections (2) and (3) set out who is the transferor on conversion of securities or on the redemption of variable rate securities, as these are transactions under which the securities cease to exist rather than a transfer of a holding which continues to exist. The other party to the transaction, the issuer of the securities who has converted or redeemed them, is accordingly not treated as a transferee for the purposes of the Chapter.

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