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49Section 684 of ITA 2007 (person liable to counteraction of income tax advantage) does not apply to a person if—
(a)that section would (ignoring this paragraph) only apply to the person as a result of the person being a party to a transaction in securities, or two or more transactions in securities, where the securities in question are securities of a QAHC, and
(b)the securities are not qualifying employment-related securities (within the meaning given by paragraph 47(3)) in relation to the person.
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