Commentary

D9.526 Definition of corporate strips

Corporate tax
Corporate tax | Commentary

D9.526 Definition of corporate strips

Corporate tax | Commentary

D9.526 Definition of corporate strips

Any interest-bearing corporate security (ie any interest-bearing security (ie loan stock or similar) other than a government security or a share in a company1) can be converted into a corporate strip, if2:

  1.  

    (a)     the conversion takes place under any scheme or arrangement such that the holder comes to have two or more separate assets in place of the original corporate security;

  2.  

    (b)     each of those separate assets represents a right to, or can secure one or more, stripped payments;

  3.  

    (c)     all of the assets taken together represent a right to, or can secure, every payment

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