177 Dividend stripping

177  Dividend stripping

(1)     The provisions of this section apply where one company (“the first company”) has a holding in another company (“the second company”) and the following conditions are fulfilled—

(a)     that the holding amounts to, or is an ingredient in a holding amounting to, 10 per cent of all holdings of the same class in the second company,

(b)     that the first company is not a dealing company in relation to the holding,

(c)     that a distribution is or has been made to the first company in respect of the holding, and

(d)     that the effect of the distribution is that the value of the holding is or has been materially reduced.

(2)     Where this section applies in relation to a holding, section 176 shall apply, subject

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