695 Transfers of value to connected companies
Corporation Tax Act 2009 (2009 c 4) | Legislation

695  Transfers of value to connected companies

(1)     This section applies if—

(a)     a company (“A”) paid an amount (“amount X”) to a company (“B”) for the grant of an option,

(b)     there is a failure to exercise in full all the rights under the option,

(c)     until the failure the option was a derivative contract of A,

(d)     as a result of the failure there is a transfer of value by A to B,

(e)     B is a connected company in relation to A, and

(f)     B is not chargeable

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