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Link to original content: http://www.legislation.gov.uk/ukpga/2005/5/section/456/7
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(1)No loss is taken to occur for the purposes of section 454 on a transfer of a deeply discounted security to a person connected with the transferor if conditions A and B and either condition C or conditions D and E are met.
(2)Condition A is that the transferor acquired the security on its issue.
(3)Condition B is that the amount paid by the transferor to acquire the security exceeded the market value of the security at the time of its issue.
(4)Condition C is that at that time the transferor was connected with the issuer.
(5)Condition D is that at that time the issuer was a close company.
(6)Condition E is that at that time the transferor controlled that company with other persons to whom securities of the same kind were also issued.
[F1(7)Chapter 2 of Part 10 of CTA 2010 (meaning of “close company”) applies for the purposes of this section but with the omission of section 442(a) (exclusion of non-UK resident companies).]
(8)In this section “control” has the meaning given by [F2sections 450 and 451 of CTA 2010].
Textual Amendments
F1S. 456(7) substituted (1.4.2010) (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 466(2) (with Sch. 2)
F2Words in s. 456(8) substituted (1.4.2010) (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 466(3) (with Sch. 2)
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