HMRC Note - Purchase of own shares – multiple completion contracts

HMRC have provided us with the attached note which clarifies their position on the purchase of own shares legislation at s1033 Corporation Tax Act (CTA) 2010 where the transaction is effected through a multiple completion contract and whether the seller remains connected with the company immediately after the purchase, in particular their view that the word ‘possesses’ in s1062(2) CTA 2010 refers to legal, as opposed to beneficial, ownership.