Section 734 — Corporation Tax Act 2010: Exception where no tax avoidance object shown

Exception where no tax avoidance object shown 734 1 Section 733 does not apply to a company in respect of a transaction in securities or two or more such transactions if the company shows that the transaction or transactions meet conditions A and B.

2 Condition A is that the transaction or transactions are effected—

a for genuine commercial reasons, or b in the ordinary course of making or managing investments.

3 Condition B is that enabling corporation tax advantages to be obtained is not the main object or one of the main objects of the transaction or, as the case may be, any of the transactions.