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HMRC internal manual

Capital Gains Manual

Co.purchases own shares: capital treatment: Condition A

CTA10/S1033(2) states that for Condition A to be met, the purchase of own shares must be

  • wholly or mainly made for benefitting a trade carried on by the company or its 75% subsidiaries, and
  • it must not form part of a scheme or arrangement the main purpose or one of the main purposes of which is to enable the owner of the shares to participate in the profits of the company without receiving a dividend or the avoidance of tax.

Additionally, the requirements detailed in CG58640 to CG58644 need to be met.