153 Arm's length provision where security issued and guarantee given
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

153  Arm's length provision where security issued and guarantee given

(1)     This section applies where the actual provision is made or imposed by means of a series of transactions which include—

(a)     the issuing of a security by a company which is one of the affected persons (“the issuing company”), and

(b)     the provision of a guarantee by a company which is the other affected person.

(2)     Section 147(1)(d) is to be read as requiring account to be taken of all

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