Section 684 | Person liable to counteraction of income tax advantage

(1)This section applies to a person (“the party”) where—

(a)the person is a party to a transaction in securities or two or more transactions in securities (see subsection (2)),

(b)the circumstances are covered by section 685 and not excluded by section 686,

(c)the main purpose, or one of the main purposes, of ... the transaction in securities, or any of the transactions in securities, is to obtain an income tax advantage, and

(d)the party or any other person obtains an income tax advantage in consequence of the transaction or the combined effect of the transactions.

(2)In this Chapter “transaction in securities” means a transaction, of whatever description, relating to securities, and includes in particular—

(a)the purchase, sale or exchange of securities,

(b)issuing or securing the issue of new securities,

(c)applying or subscribing for new securities, ...

(d)altering or securing the alteration of the rights attached to securities.

(e)a repayment of share capital or share premium, and

(f)a distribution in respect of securities in a winding up.

(3)Section 687 defines “income tax advantage”.

(4)This section is subject to no-counteraction notices issued under section 698A.