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Legislation
Taxation of Chargeable Gains Act 1992

Chapter III Miscellaneous provisions relating to commodities, futures, options and other securities

  • Section 142 Capital gains on stock dividends.
  • Section 142A REITs: chargeable gains on stock dividends
  • Section 143 Commodity and financial futures and qualifying options.
  • Section 144 Options and forfeited deposits.
  • Section 144ZA Application of market value rule in case of exercise of option
  • Section 144ZB Exception to rule in section 144ZA
  • Section 144ZC Section 144ZB: non-commercial exercise of option
  • Section 144ZD Section 144ZB: alteration of value to obtain tax advantage
  • Section 144A Cash-settled options.
  • Section 145 Call options: indexation allowance.
  • Section 146 Options: application of rules as to wasting assets.
  • Section 147 Quoted options treated as part of new holdings.
  • Section 148 Traded options: closing purchases.
  • Section 148A Futures and options involving guaranteed returns
  • Section 148B Deemed disposals at a gain under section 564(4) of ITTOIA 2005
  • Section 148C Deemed disposals at a loss under section 564(4) of ITTOIA 2005
  • Section 149 Rights to acquire qualifying shares.
  • Section 149A Employment-related securities options
  • Section 149AA Restricted and convertible employment-related securities and employee shareholder shares
  • Section 149AB Shares in research institution spin-out companies
  • Section 149B Employee incentive schemes: conditional interests in shares.
  • Section 149C Priority share allocations
  • Section 150 Business expansion schemes.
  • Section 150A Enterprise investment scheme.
  • Section 150B Enterprise investment scheme: reduction of EIS relief.
  • Section 150C Enterprise investment scheme: re-investment.
  • Section 150D Enterprise investment scheme: application of taper relief
  • Section 150E Seed enterprise investment scheme
  • Section 150F Seed enterprise investment scheme: reduction of relief
  • Section 150G Seed enterprise investment scheme: re-investment
  • Section 151 Personal equity plans.
  • Section 151A Venture capital trusts: reliefs.
  • Section 151B Venture capital trusts: supplementary.
  • Section 151BA CITR: identification of securities or shares on a disposal
  • Section 151BB CITR: rights issues etc
  • Section 151BC CITR: company reconstructions etc
  • Section 151C Strips: manipulation of price: associated payment giving rise to loss
  • Section 151D Corporate strips: manipulation of price: associated payment giving rise to loss
  • Section 151E Exchange gains and losses from loan relationships: regulations
  • Section 151F Treatment of alternative finance arrangements
  • Section 151G Regulations where non-qualifying shares conditions altered
  1. Chapter III · Miscellaneous provisions relating to commodities, futures, options and other securities
  2. Corporate strips: manipulation of price: associated payment giving rise to loss

Section 151D | Corporate strips: manipulation of price: associated payment giving rise to loss F1

From legislation.gov.uk

(1)This section applies if—

(a)as a result of any scheme or arrangement which has an unallowable purpose, the circumstances are, or might have been, as mentioned in paragraph (a), (b) or (c) of section 452G(2) of ITTOIA 2005,

(b)under the scheme or arrangement, a payment falls to be made otherwise than in respect of the acquisition or disposal of a corporate strip, and

(c)as a result of that payment or the circumstances in which it is made, a loss accrues to any person.

(2)The loss shall not be an allowable loss.

(3)For the purposes of this section a scheme or arrangement has an unallowable purpose if the main benefit, or one of the main benefits, that might have been expected to result from, or from any provision of, the scheme or arrangement (apart from section 452G of ITTOIA 2005 and this section) is—

(a)the obtaining of a tax advantage by any person, or

(b)the accrual to any person of an allowable loss.

(4)The reference in subsection (1)(b) above to the acquisition or disposal of a corporate strip shall be construed as if it were in Chapter 8 of Part 4 of ITTOIA 2005 (profits from deeply discounted securities) (see, in particular, sections 437 and 452F of that Act for the meaning of “disposal” and section 452E of that Act for the meaning of “corporate strip”).

(5)In subsection (3)(a) above “tax advantage” has the meaning given by section 1139 of CTA 2010.F2

(6)This section applies to losses accruing on or after 6th April 2005.

Notes

  1. F1

    S. 151D inserted (20.7.2005) by Finance (No. 2) Act 2005 (c. 22), Sch. 7 para. 8

  2. F2

    Words in s. 151D(5) substituted (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. 239 (with Sch. 2)

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