Corporation Tax Act 2010 section 1114

"In respect of securities"

Section 1114 defines what "in respect of securities of the company" means for the purposes of Part 23, including how the concept extends across 90% groups and how advances without formal securities are treated.

• Where a company belongs to a 90% group, "in respect of securities of the company" covers securities of that company and any other company in the same group, but this extended meaning does not force a company to be treated as making a distribution to a UK-resident group member.
• Interest paid on money advanced without a formal security being issued, or any other consideration given for the use of such money, is treated as though it were paid or given in respect of a security issued by the company for that advance.
• An action is regarded as done "in respect of a security" if it is done to a person as the current holder of the security or as someone who held it at a particular time.
• An action is also regarded as done "in respect of a security" if it is carried out in pursuance of a right granted or an offer made in connection with a security.