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Part 6U.K.Tax arbitrage

Modifications etc. (not altering text)

C1Pt. 6 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)

C2Pt. 6 excluded by 2010 c. 4, s. 938V(c) (as inserted (with effect in accordance with Sch. 20 para. 6 of the amending Act) by Finance Act 2013 (c. 29), Sch. 20 para. 3)

Deduction schemesU.K.

238Shares subject to conversionU.K.

(1)A scheme is a deduction scheme if it includes—

(a)a company issuing shares subject to conversion, or

(b)such an amendment of rights attaching to shares issued by a company that the shares become shares subject to conversion.

(2)For the purposes of subsection (1)(a) a company's shares are shares subject to conversion if conditions A and B are met.

(3)For the purposes of subsection (1)(b) a company's shares are shares subject to conversion if conditions A and C are met.

(4)Condition A is that the rights attached to the shares include provision as a result of which a holder of such shares is entitled, on the occurrence of an event, to acquire securities in a company by conversion or exchange.

(5)Condition B is that at the time when the shares are issued the company could reasonably expect that event to occur.

(6)Condition C is that at the time when the rights attaching to the shares are amended as described in subsection (1)(b) the company could reasonably expect that event to occur.