Part 15U.K.Deduction of income tax at source

Chapter 9U.K.Manufactured payments

[F1ReposU.K.

Textual Amendments

F1Ss. 925A-925F and cross-heading inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 7 para. 112 (with Sch. 9 paras. 1-9, 22)

925FInterpretation of the repo sectionsU.K.

(1)This section applies for the purposes of sections 925A to 925E and this section.

(2)Arrangement” includes any agreement or understanding (whether or not legally enforceable).

(3)It does not matter whether or not provision of any arrangement conferring a right or imposing an obligation on any person to buy any securities is subject to any conditions.

(4)Securities” means shares, stock or other securities issued by—

(a)the government of the United Kingdom,

(b)any public or local authority in the United Kingdom,

(c)any UK resident company or other UK resident body,

(d)a government or public or local authority of a territory outside the United Kingdom, or

(e)any other body of persons not resident in the United Kingdom.

(5)Securities are similar if they give their holders—

(a)the same rights against the same persons as to capital, interest and dividends, and

(b)the same remedies to enforce those rights.

(6)Subsection (5) applies even if there is a difference in—

(a)the total nominal amounts of the securities,

(b)the form in which they are held, or

(c)the manner in which they can be transferred.

(7)If—

(a)a person (“A”) buys securities (or has a right or obligation to buy securities), but

(b)the securities are (or are to be) held for the benefit of another person (“B”),

B (not A) is treated as buying (or having the right or obligation to buy) the securities.

(8)If—

(a)a person (“C”) sells securities, but

(b)the proceeds of the sale are held for the benefit of another person (“D”),

D (not C) is treated as selling the securities.]