[396A Arrangements offering a choice of capital or income return]

[Other amounts treated as distributions]

[396A  Arrangements offering a choice of capital or income return]

[(1)     Subsection (2) applies if a person (“S”) has a choice either—

(a)     to receive what would (ignoring this section) be a distribution of a company, or

(b)     to receive from that company, or from a third party, anything else (“the alternative receipt”) which—

(i)     is of the same or substantially the same value, and

(ii)     (ignoring this section) would not be charged to income tax.

(2)

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