{
  "url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-456",
  "json_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-456.json",
  "legislation": "ukpga/2005/5",
  "legislation_title": "Income Tax (Trading and Other Income) Act 2005",
  "legislation_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005",
  "path": "section/456",
  "kind": "section",
  "number": "456",
  "heading": "Securities issued to connected persons etc. at excessive price: subsequent transfers to connected persons",
  "text": "(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.\n(2) Condition A is that the transferor acquired the security on its issue.\n(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.\n(4) Condition C is that at that time the transferor was connected with the issuer.\n(5) Condition D is that at that time the issuer was a close company.\n(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.\n(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).\n(8) In this section “control” has the meaning given by sections 450 and 451 of CTA 2010.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "S. 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)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words 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)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2005/5/section/456",
    "retrieved_at": "2026-10-29T09:16:32.370392+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."
}