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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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Authorised investment funds (AIFs): taxation of funds: trading or investment - ‘investment transactions’ - securities

SI2006/964 Regulation 14F(1)(e) & (2) - securities of any description

Regulation 14F(1)(e) provides that any transaction in securities is an investment transaction for the purposes of regulation 14E.

A transaction in securities for the purposes of regulation 14F(1)(e) is any transaction in securities of any description not otherwise falling within any of regulations 14F(1)(a) (stocks and shares), 14F(1)(b) (relevant contracts), 14F(1)(c) (loan relationships) and 14F(1)(d) (units in a collective investment scheme). This formulation gives ‘securities’ a wide meaning and makes regulation 14F(1)(e) residual: equity and debt instruments, for example, although securities in the wider sense of the term, will not come within regulation 14F(1)(e) if they fall within regulation 14F(1)(a) or regulation 14F(1)(c) respectively.