CTM36825 - Particular topics: transactions in securities: circumstance A- abnormal dividend used for exemptions or reliefs

Circumstance A is present when a person receives an abnormal dividend, (or other qualifying distributions or interest), taken into account for any of the purposes:

• listed in ITA07/S686 where an income tax advantage has been obtained on or after 6 April 2007
• listed in ICTA88/S704A (a) - (g) where an income tax advantage has been obtained prior to 6 April 2007 or corporation tax advantages have been obtained in an accounting period ending before 6 April 2007
• listed in ICTA88/S704A (a) - (da) for corporation tax purposes for accounting periods ending after 5 April 2007.

The purposes listed include exemption from income tax, setting off of losses against profits and giving relief for interest payments and avoidance of franked investment income for the purposes of shadow ACT.