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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Particular topics: transactions in securities: 'circumstances’ and relevant consideration

‘Circumstances’

Certain ‘circumstances’, set out in ITA07/S685, must be satisfied before the legislation can be applied to a transaction in securities.

These ‘circumstances’ are where condition A (see CTM36822) or condition B (see CTM36823) set out in the legislation are met.

Both conditions relate to close companies, see CTM60060.  But for this purpose the definition has been extended to include a company that would be a close company if it were resident in the UK (ITA07/S809ZQ).

Each condition has its own definition of relevant consideration.

Relevant consideration

The relevant consideration is the amount received by the person as a result of the transaction or transactions in securities which can be taken into account in determining any tax charge under the transactions in securities provisions.  It will include both money and money’s worth.

The amount of relevant consideration depends on whether it is condition A or condition B that is being applied.  See CTM36822 and CTM36823.