Income Tax (Trading and Other Income) Act 2005 section 79

Deeply discounted securities issued in accordance with qualifying earn-out right

Section 79 preserves the application of rules on deeply discounted securities issued under qualifying earn-out rights, regardless of when the security was issued, despite the repeal of an earlier provision.

• The repeal of section 104(4) of the Finance Act 2002 by ITTOIA 2005 does not affect the rules on securities issued under qualifying earn-out rights
• Section 430(5) of ITTOIA 2005, which deals with the meaning of deeply discounted securities, continues to apply without restriction on timing
• Section 442 of ITTOIA 2005, which covers securities issued in accordance with qualifying earn-out rights, also continues to apply regardless of issue date
• These provisions apply whenever the security was issued, ensuring no gap in coverage as a result of the legislative changeover