Section 931O | Schemes involving payments for distributions

(1)This section applies to a dividend or other distribution that would, apart from this section, fall into an exempt class.

(2)The distribution does not fall into an exempt class if—

(a)the distribution is made as part of a tax advantage scheme, and

(b)the following condition is met.

(3)The condition is that the scheme includes a payment, or the giving up of a right to income, by a relevant person where—

(a)the payment is made, or the right to income is given up, under a liability incurred for consideration in money or money's worth all or any of which consists of, or of the right to receive, the distribution, and

(b)in the case of a payment, the conditions in subsections (2) and (4) to (7) of section 1301 (restriction of deductions for annual payments) apply to the payment.