Corporation Tax Act 2010 section 1016

Meaning of "equity note" in section 1015

Section 1016 defines what constitutes an "equity note" for the purposes of the special securities rules in section 1015(6).

• A security is an equity note if it meets any one of four tests, applied to the whole or any part of its principal amount.
• The tests focus on whether the security has no fixed redemption date, or has a redemption date falling beyond 50 years from the date of issue (the "permitted period").
• A security also qualifies if redemption is triggered by an event expected to occur after the permitted period, or if the issuing company can control the timing to push redemption beyond that period.
• The permitted period is 50 years beginning from the date the security is issued.