Capital Gains: Is the issue or redemption of redeemable preference shares taken into account in determining the application of section 160ZZS?

The issue or redemption of redeemable preference shares by a company will be taken into account in applying the majority underlying interest test in section 160ZZS unless on the facts, the arrangement is seen to be a financing arrangement and treated as such by the parties for all purposes (including the section 46 rebate).