Income Tax (Trading and Other Income) Act 2005 section 452A

Application of this Chapter to corporate strips

Section 452A establishes that all corporate strips are automatically treated as deeply discounted securities and sets out which additional rules apply to them.

• All corporate strips are treated as deeply discounted securities, regardless of whether they would naturally qualify as such.
• The deeply discounted securities rules in Chapter 8 apply to corporate strips in full.
• Special rules on how acquisitions and disposals of corporate strips are handled also apply (section 452F).
• Anti-avoidance rules targeting the manipulation of acquisition, transfer or redemption payments for corporate strips must also be observed (section 452G).