Corporation Tax Act 2010 section 265

Meaning of "issue of securities or shares"

Section 265 defines what constitutes an "issue of securities" and an "issue of shares" for the purposes of this part of the Act, and clarifies what it means when securities or shares are issued to a particular company.

• An "issue of securities" of a body means all securities of that body that carry the same rights, are issued on the same terms, and are issued on the same day.
• An "issue of shares" in a body means all shares in that body that are of the same class and are issued on the same day.
• Where the legislation refers to an issue of securities or shares to a particular company, it means only those securities or shares within the issue that are issued to that company acting in one specific capacity.
• These definitions ensure that groupings of securities and shares are treated consistently when applying the loan relationship and derivative contract rules in this part of the Act.