247Timing of transfers of interestsU.K.
(1)Where ownership interests in an entity are transferred from one entity or individual to another entity or individual, that transfer is to be treated as effective at the earlier of—
(a)the time when the obligations of the parties to the transfer necessary to effect the transfer have been met, and
(b)the time when any of the substantive consideration for the transfer has been provided,
(instead of at any earlier time when the transfer is effective).
(2)In subsection (1)(b) the reference to “substantive consideration” means any amount of the consideration for the transfer other than any amount provided before the transfer which would not be refundable if the transfer did not take place as a result of the transferee not meeting its obligations under the arrangements to make the transfer.