150. Liability to counteraction of tax advantage from transactions in securities.

Provision is made1 for counteracting income tax and corporation tax advantages from transactions in securities2. The income tax provisions apply to a person ('the party')3 where:

  1.  

    (1)     the person is a party to a transaction in securities or two or more transactions in securities4;

  2.  

    (2)     the circumstances are within the specified category5;

  3.  

    (3)     the main purpose, or one of the main purposes, of the transaction in securities, or any of the transactions in securities, is to obtain an income tax advantage; and

  4.  

    (4)     the party or any other person obtains an income tax advantage in consequence of the transaction