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Taxation (International and Other Provisions) Act 2010
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239Securities subject to conversion
This section has no associated Explanatory Notes
(1)A scheme is a deduction scheme if it includes—
(a)a company issuing securities subject to conversion, or
(b)such an amendment of rights attaching to securities issued by a company that the securities become securities subject to conversion.
(2)For the purposes of subsection (1)(a) a company’s securities are securities subject to conversion if conditions A and B are met.
(3)For the purposes of subsection (1)(b) a company’s securities are securities subject to conversion if conditions A and C are met.
(4)Condition A is that the rights attached to the securities include provision as a result of which a holder of such securities is entitled, on the occurrence of an event, to acquire shares in a company by conversion or exchange.
(5)Condition B is that at the time when the securities 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 securities are amended as described in subsection (1)(b) the company could reasonably expect that event to occur.
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