{
  "url": "https://openlegislation.uk/finance-act-1990/schedule-10/paragraph-27",
  "json_url": "https://openlegislation.uk/finance-act-1990/schedule-10/paragraph-27.json",
  "legislation": "ukpga/1990/29",
  "legislation_title": "Finance Act 1990",
  "legislation_url": "https://openlegislation.uk/finance-act-1990",
  "path": "schedule/10/paragraph/27",
  "kind": "paragraph",
  "number": "27",
  "heading": null,
  "text": "(1) Schedule 11 to the Finance Act 1989 (deep gain securities) shall be amended as follows.\n(2) In paragraph 4 (meaning of transfer etc.) the following sub-paragraph shall be inserted after sub-paragraph (2)—\n“(2A) But (notwithstanding sub-paragraph (2) above) “transfer” does not include a transfer made on a conversion of a security into share capital in a company.”\n(3) The following shall be inserted after paragraph 22—\n“ Convertible securities: special rules (1)\n22A (1) Sub-paragraph (2) below applies where—\n(a) a security is a qualifying convertible security, for the purposes of Schedule 10 to the Finance Act 1990, at the time of its issue,\n(b) apart from paragraph 21 of Schedule 4 to the Taxes Act 1988, it would be a deep discount security at that time, and\n(c) at a later time it ceases to be a qualifying convertible security for the purposes of Schedule 10 to the Finance Act 1990.\n(2) As regards any event occurring in relation to the security after the time mentioned in sub-paragraph (1)(c) above, paragraphs 5 to 19 above shall have effect as if—\n(a) the security were a deep gain security, and\n(b) it had been acquired as such (whatever the time it was acquired).\n(3) For the purposes of sub-paragraph (2) above events, in relation to a security, include anything constituting a transfer or acquisition for the purposes of this Schedule.\nConvertible securities: special rules (2)\n22B (1) In a case where—\n(a) a security is a qualifying convertible security, for the purposes of Schedule 10 to the Finance Act 1990, at the time of its issue, and\n(b) apart from this sub-paragraph it would be a deep gain security at that time,\nthen (subject to sub-paragraph (3) below) the security shall be treated, at the time of its issue and at all subsequent times, as not being a deep gain security.\n(2) Sub-paragraph (3) below applies where—\n(a) sub-paragraph (1) above applies in the case of a security, and\n(b) at a time after its issue it ceases to be a qualifying convertible security for the purposes of Schedule 10 to the Finance Act 1990.\n(3) As regards any event occurring in relation to the security after the time mentioned in sub-paragraph (2)(b) above, paragraphs 5 to 19 above shall have effect as if—\n(a) the security were a deep gain security, and\n(b) it had been acquired as such (whatever the time it was acquired).\n(4) For the purposes of sub-paragraph (3) above events, in relation to a security, include anything constituting a transfer or acquisition for the purposes of this Schedule.”",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "M",
      "label": "M1",
      "text": "1989 c. 26."
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1990/29/schedule/10/paragraph/27",
    "retrieved_at": "2026-10-29T09:43:04.265975+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}