Section 931L Schemes involving manipulation of portfolio holdings ruleF1

(1)

This section applies to a dividend or other distribution that would, apart from this section, fall into an exempt class by virtue of section 931G.

(2)

The distribution does not fall into an exempt class by virtue of that section if—

(a)

the distribution is made as part of a scheme the main purpose, or one of the main purposes, of which is to secure that distributions of the payer received by the recipient fall into an exempt class by virtue of that section, and

(b)

the following condition is met.

(3)

The condition is that the distribution would not fall into an exempt class by virtue of section 931G if the reference in subsection (1) of that section to the recipient were to all relevant persons taken together.

Annotations

Textual amendments

F1: Pt. 9A inserted (with effect in accordance with Sch. 14 para. 31 of the amending Act) by Finance Act 2009 (c. 10), Sch. 14 para. 1 (with Sch. 14 para. 32)

Notes on Part 9A

Modifications

C1: Pt. 9A modified (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), ss. 787, 795, 1184(1) (with Sch. 2)
C2: Pt. 9A modified by 2010 c. 4, s. 814D(6) (as inserted (with effect in accordance with Sch. 29 para. 51 of the amending Act) by Finance Act 2013 (c. 29), Sch. 29 para. 2)