Section 931O — Corporation Tax Act 2009: Schemes involving payments for distributions

Schemes involving payments for distributions 931O 1 This section applies to a dividend or other distribution that would, apart from this section, fall into an exempt class.

2 The distribution does not fall into an exempt class if—

a the distribution is made as part of a tax advantage scheme, and b the following condition is met.

3 The condition is that the scheme includes a payment, or the giving up of a right to income, by a relevant person where—

a the payment is made, or the right to income is given up, under a liability incurred for consideration in money or money's worth all or any of which consists of, or of the right to receive, the distribution, and b in the case of a payment, the conditions in subsections (2) and (4) to (7) of section 1301 (restriction of deductions for annual payments) apply to the payment.