Commentary

D9.504 Disposals

Corporate tax
Corporate tax | Commentary

D9.504 Disposals

Corporate tax | Commentary

D9.504 Disposals

For the purpose of these rules, a disposal of a DDS takes place:

  1.  

    (a)     on its redemption (but see D9.505);

  2.  

    (b)     on its transfer by sale, exchange, gift or otherwise;

  3.  

    (c)     on its conversion under its terms into other securities (including other DDSs) or company shares;

  4.  

    (d)     on the holder's death, whereupon it is treated as transferred to the personal representative immediately before death1.

The person treated as making the disposal is:

  1.  

    (i)     in a case within head (a) above, the person entitled to any payment on the disposal;

  2.  

    (ii)     in a case within head (b) above, the transferor;

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