Section 931L — Corporation Tax Act 2009: Schemes involving manipulation of portfolio holdings rule

Schemes involving manipulation of portfolio holdings rule 931L 1 This section applies to a dividend or other distribution that would, apart from this section, fall into an exempt class by virtue of section 931G.

2 The distribution does not fall into an exempt class by virtue of that section if—

a the distribution is made as part of a scheme the main purpose, or one of the main purposes, of which is to secure that distributions of the payer received by the recipient fall into an exempt class by virtue of that section, and b the following condition is met.

3 The condition is that the distribution would not fall into an exempt class by virtue of section 931G if the reference in subsection (1) of that section to the recipient were to all relevant persons taken together.