146. Interest or other distribution paid in respect of certain securities.

Any interest or other distribution which:

  1.  

    (1)     is paid out of the assets of a company ('the borrower') to another company which is within the charge to corporation tax; and

  2.  

    (2)     is so paid in respect of special securities1 of the borrower; and

  3.  

    (3)     is not a distribution in respect of non-commercial securities