[259DB Meaning of “hybrid transfer arrangement”, “underlying instrument” etc]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259DB  Meaning of “hybrid transfer arrangement”, “underlying instrument” etc]

[(1)     This section has effect for the purposes of this Chapter.

(2)     A “hybrid transfer arrangement” means—

(a)     a repo,

(b)     a stock lending arrangement, or

(c)     any other arrangement,

that is an arrangement within subsection (3).

(3)     An arrangement is within this subsection if it provides for, or relates to, the transfer of a financial instrument (“the underlying instrument”) and—

(a)     the dual treatment condition is met in relation to the arrangement, or

(b)     a substitute payment could be made under the arrangement.

(4)     The dual treatment

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