Income Tax Act 2007

621 Transferors and transferees

(1) In this Chapter “transferor” and “transferee” are to be read in accordance with section 620 (but this is subject to subsections (2) to (4)).

(2) In the case of a conversion of securities within section 620(1)(b)—

(a) the person who was entitled to the securities immediately before the conversion is treated as the transferor, but

(b) no one is treated as the transferee.

(3) In the case of a redemption of securities within section 620(1)(c)—

(a) the person who was entitled to the securities immediately before the redemption is treated as the transferor, but

(b) no one is treated as the transferee.

(4) The following provisions also contain rules about who is the transferor or the transferee for certain transfers—

• section 648(1) to (4) (strips of gilt-edged securities),

• section 649(4) and (5) (new securities issued with extra return),

• section 650 (trading stock appropriations etc),

• section 651(2) and (3) (owner becoming entitled to securities as trustee),

• section 652(2) and (3) (securities ceasing to be held on charitable trusts), and

• section 666 (certain transfers by or to nominees or trustees treated as made by or to others).

(5) See also sections 638 to 647 (excluded transferors and transferees).