[263E Structured finance arrangements]

[263E  Structured finance arrangements]

[(1)     This section applies if—

(a)     [section 809BZB or 809BZC of ITA 2007] [or section 759 or 760 of CTA 2010] (disregard of intended effects of arrangement involving disposals of assets) applies in relation to a structured finance arrangement,

(b)     the borrower or a person connected with the borrower makes a disposal of any security at any time under the arrangement to or for the benefit of the lender or a person connected with the lender, and

(c)     condition A or B is met.

(2)     Condition A is that the person making the disposal [(and no-one else) has the right or obligation under the arrangement to acquire the asset disposed

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