Part 4

Savings and investment income
Chapter 8

Profits from deeply discounted securities

Special rules for corporate strips

Conversion of interest-bearing corporate securities into corporate strips
452C
1
For the purposes of this Chapter a person converts an interest-bearing corporate security into corporate strips of the security if he has an interest-bearing corporate security (“
the converted corporate security
”) but—
a
as a result of any scheme or arrangements, he acquires two or more separate assets in place of the converted corporate security,
b
each of those separate assets satisfies condition A,
c
those separate assets, taken together, satisfy condition B, and
d
at least one of those separate assets is not prevented from being a corporate strip by section 452E(2) or (3),
and related expressions shall be construed accordingly.
2
Condition A is that the asset—
a
represents the right to, or
b
secures,
one or more stripped payments.
3
For the purposes of this section, a “
stripped payment
” is—
a
the payment of, or
b
a payment corresponding to,
the whole or a part of one or more payments (whether of interest or principal) remaining to be made under the converted corporate security.
4
Condition B is that the assets, taken together,—
a
represent the right to, or
b
secure,
every payment (whether of interest or principal) remaining to be made under the converted corporate security (or payments corresponding to every such payment).
5
Where a person—
a
has an interest-bearing corporate security, but
b
sells or transfers the right to one or more payments remaining to be made under it (so that, as a result, there are two or more separate assets which, taken together, satisfy condition B),
this Chapter has effect as if, as a result of a scheme or arrangements, the person had acquired the separate assets in place of the security immediately before the sale or transfer.
6
After a balance has been struck for a dividend on an interest-bearing corporate security, any payment to be made in respect of that dividend shall, at times falling after that balance has been struck, be treated for the purposes of this paragraph as not being a payment remaining to be made under the security.
Ss. 452A-452G and preceding cross-heading inserted (retrospectively) by Finance (No. 2) Act 2005 (c. 22), s. 39, Sch. 7 para. 25(8)(10)
Ss. 452A-452G and preceding cross-heading inserted (retrospectively) by Finance (No. 2) Act 2005 (c. 22), s. 39, Sch. 7 para. 25(8)(10)
Pt. 4 Ch. 8 applied (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), ss. 406(4), 1329(1) (with Sch. 2 Pts. 1, 2)