Section 925F — Income Tax Act 2007: Interpretation of the repo sections

Interpretation of the repo sections 925F 1 This section applies for the purposes of sections 925A to 925E and this section. 2 “ Arrangement ” includes any agreement or understanding (whether or not legally enforceable).

3 It does not matter whether or not provision of any arrangement conferring a right or imposing an obligation on any person to buy any securities is subject to any conditions. 4 “ Securities ” means shares, stock or other securities issued by—

a the government of the United Kingdom, b any public or local authority in the United Kingdom, c any UK resident company or other UK resident body, d a government or public or local authority of a territory outside the United Kingdom, or e any other body of persons not resident in the United Kingdom.

5 Securities are similar if they give their holders—

a the same rights against the same persons as to capital, interest and dividends, and b the same remedies to enforce those rights.

6 Subsection (5) applies even if there is a difference in—

a the total nominal amounts of the securities, b the form in which they are held, or c the manner in which they can be transferred.

7 If—

a a person (“A”) buys securities (or has a right or obligation to buy securities), but b the securities are (or are to be) held for the benefit of another person (“B”), B (not A) is treated as buying (or having the right or obligation to buy) the securities.

8 If—

a a person (“C”) sells securities, but b the proceeds of the sale are held for the benefit of another person (“D”), D (not C) is treated as selling the securities.