Commentary

D9.530 Securities issued in separate tranches

Corporate tax
Corporate tax | Commentary

D9.530 Securities issued in separate tranches

Corporate tax | Commentary

Special cases

D9.530 Securities issued in separate tranches

Where securities are issued under a prospectus in separate tranches, some of them may be issued at a deep discount and others not issued at a deep discount. Special rules apply to determine which of such issues are to be treated as DDSs.

1. The 'basic rule' is that if an issue under the prospectus is not at a deep discount, that issue and any later issues under the same prospectus are not treated as DDSs. This does not apply to securities in a later issue which were issued at a deep discount to a person connected with the issuer or such a person has acquired the securities; such securities are treated as DDSs1.

Example 1

Alpha Ltd made the following issues of securities, all for redemption on 31 March

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