(1) any property, rights or liabilities are transferred under a transfer scheme1 to a transferee2 which at the time of the transfer is a company wholly owned by the Crown3;
(2) at a time after the transfer the transferee is a company whose shares or debentures are included in the Official List4; and
(3) immediately before its shares or debentures are admitted to the Official List the transferee is wholly owned by the Crown5,
then the transferee is taken to have paid a dividend
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