410. Distributions in respect of non-redeemable ordinary shares.

A dividend or other distribution1 falls into an exempt class2 if it is made in respect of a share that is an ordinary share3 which is not redeemable4.

A dividend or other distribution that would otherwise fall within an exempt class by virtue of the above provision5 does not fall into an exempt class by virtue of that provision if the distribution is made as part of a scheme the main purpose, or one of the main purposes, of which is to secure that distributions of the payer received by the recipient fall into an exempt class by virtue of