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These provisions apply for corporation tax purposes. For details of the income tax regime see ·¡1.1417–E1.1419.

Counteraction under the anti-avoidance legislation can only be taken against a taxpayer if he is in a position to obtain or has obtained a tax advantage (see E1.1441) in consequence of¹:

1. Ìý

   •ÌýÌýÌýÌý a transaction in securities, or

2. Ìý

   •ÌýÌýÌýÌý the combined effect of two or more transactions in securities, or

3. Ìý

   •ÌýÌýÌýÌý the combined effect of one or more transactions in securities and the liquidation of a company²

The expression 'transaction in securities' has a very wide meaning and includes transactions of whatever description relating to securities, in particular the purchase, sale or exchange of securities, the issuing or securing the issue of new securities, applying or subscribing for new securities or altering or securing the alteration of the rights attached to securities³. Securities includes shares and stock, and, in relation to a company not limited by shares, to an interest of a member of the company