108 Identification of relevant securities [for corporation tax]

108  Identification of relevant securities [for corporation tax]

[(A1)     This section has effect for the purposes of corporation tax where any relevant securities are disposed of by a company.]

(1)     In this section “relevant securities” means—

(a)     securities, within the meaning of [Chapter 2 of Part 12 of ITA 2007 (accrued income profits)];

[(aa)     qualifying corporate bonds;]

(b)     . . . and

(c)     securities which are. . . [interests in a non-reporting fund, within the meaning of regulations [under section 354(1) of TIOPA 2010] (see Part 2 of the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001))];

and shares or securities of a company shall not be treated for the purposes of this section as being of the same class unless they are so treated by the practice of a recognised stock exchange or would be so treated if dealt with on a recognised stock exchange.

(2)     Where a [company] disposes of relevant securities, the securities disposed of shall be identified in accordance with the rules contained in this section with the securities of the same class acquired

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