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(2) Where, in connection with or as part of any arrangement involving any conveyance referred to in subsection (1) of stock of a company, the transferee procures, either directly or indirectly, the discharge of any indebtedness of the company (in this subsection referred to as the “first-mentioned company”) or of any other company which is connected with the first-mentioned company within the meaning of section 10 of the Taxes Consolidation Act 1997, and the main or one of the main purposes of the arrangement is to secure a tax advantage, then the conveyance shall, in addition to any other payment of money or transfer of stock to which it is subject (if any), be deemed to be subject to the payment of an amount equal to the amount of such indebtedness.

(2) Where, in connection with or as part of any arrangement involving any conveyance referred to in subsection (1) of stock of a company, the transferee procures, either directly or indirectly, the discharge of any indebtedness of the company (in this subsection referred to as the “first-mentioned company”) or of any other company which is connected with the first-mentioned company within the meaning of section 10 of the Taxes Consolidation Act 1997, and the main or one of the main purposes of the arrangement is to secure a tax advantage, then the conveyance shall, in addition to any other payment of money or transfer of stock to which it is subject (if any), be deemed to be subject to the payment of an amount equal to the amount of such indebtedness.