distribution
means a direct or indirect—
| a) |
transfer by a company of money or other property of the company, other than its own shares, to or for the benefit of one more holders of any of the shares, or to the holder of a beneficial interest in any such shares, of that company or of another company within the same group of companies, whether— |
| i) |
in the form of a dividend; |
| ii) |
as a payment in lieu of a capitalisation share, as contemplated in section 47; |
| iii) |
as consideration for the acquisition— |
| aa) |
by the company of any of its shares, as contemplated in section 48; or |
| ab) |
by any company within the same group of companies, of any shares of a company within that group of companies; or |
| iv) |
otherwise in respect of any of the shares of that company or of another company within the same group of companies, subject to section 164(19); |
| b) |
incurrence of a debt or other obligation by a company for the benefit of one or more holders of any of the shares of that company or of another company within the same group of companies; or |
| c) |
forgiveness or waiver by a company of a debt or other obligation owed to the company by one or more holders of any of the shares of that company or of another company within the same group of companies, |
but does not include any such action taken upon the final liquidation of the company;
Intellectual Property Rights from Publicly Financed Research and
