they are entered into between two persons (“the first purchaser” and “the second purchaser”), one or both of whom are financial institutions, and

the first purchaser is a financial institution, and

the asset referred to in subsection (1)(b)(i) was purchased by the first purchaser for the purpose of entering into arrangements within this section.

a financial institution (“the first owner”) acquires a beneficial interest in an asset,

another person (“the eventual owner”) also acquires a beneficial interest in it,

the eventual owner is to make payments to the first owner amounting in aggregate to the consideration paid for the acquisition of the first owner's beneficial interest (but subject to any adjustment required for such a reduction as is mentioned in subsection (5)),

the eventual owner is to acquire the first owner's beneficial interest (whether or not in stages) as a result of those payments,

the eventual owner is to make other payments to the first owner (whether under a lease forming part of the arrangements or otherwise),

the eventual owner has the exclusive right to occupy or otherwise to use the asset, and

the eventual owner is exclusively entitled to any income, profit or gain arising from or attributable to the asset (including, in particular, an increase in its value).

the first owner acquires its beneficial interest from the eventual owner,

the eventual owner, or another person who is not the first owner, also has a beneficial interest in the asset, or

the first owner also has a legal interest in it.

the grant is not required by the first owner or arrangements to which the first owner is a party.

having responsibility for any reduction in the asset's value, or

having a share in a loss arising out of any such reduction.

a person (“the depositor”) deposits money with a financial institution,

the money, together with money deposited with the institution by other persons, is used by it with a view to producing a profit,

from time to time the institution makes or credits a payment to the depositor out of profit resulting from the use of the money,

the payment is in proportion to the amount deposited by the depositor, and

the payments so made or credited by the institution equate, in substance, to the return on an investment of money at interest.

a person (“the principal”) appoints an agent,

one or both of the principal and agent is a financial institution,

the agent uses money provided by the principal with a view to producing a profit,

the principal is entitled, to a specified extent, to profits resulting from the use of the money,

the agent is entitled to any additional profits resulting from its use (and may also be entitled to a fee paid by the principal), and

payments made because of the principal's entitlement to profits equate, in substance, to the return on an investment of money at interest.

they provide for one person (“the bond-holder”) to pay a sum of money (“the capital”) to another (“the bond-issuer”),

they identify assets, or a class of assets, which the bond-issuer will acquire for the purpose of generating income or gains directly or indirectly (“the bond assets”),

they specify a period at the end of which they cease to have effect (“the bond term”),

the amount of the additional payments does not exceed an amount which would be a reasonable commercial return on a loan of the capital,

under the arrangements the bond-issuer undertakes to arrange for the management of the bond assets with a view to generating income sufficient to pay the redemption payment and additional payments,

the bond-holder is able to transfer the rights under the arrangements to another person (who becomes the bond-holder because of the transfer),

the arrangements are a listed security on a recognised stock exchange, and

the arrangements are wholly or partly treated in accordance with international accounting standards as a financial liability of the bond-issuer, or would be if the bond-issuer applied those standards.

the bond-issuer may acquire bond assets before or after the arrangements take effect,

the bond assets may be property of any kind, including rights in relation to property owned by someone other than the bond-issuer,

the identification of the bond assets mentioned in subsection (1)(b) and the undertakings mentioned in subsection (1)(d) and (f) may (but need not) be described as, or accompanied by a document described as, a declaration of trust,

a reference to the management of assets includes a reference to disposal,

the bond-holder may (but need not) be entitled under the arrangements to terminate them, or participate in terminating them, before the end of the bond term,

if the amount of the additional payments is not fixed at the beginning of the bond term, the reference in subsection (1)(e) to the amount of the additional payments is a reference to the maximum amount of the additional payments,

the amount of the redemption payment may (but need not) be subject to reduction in the event of a fall in the value of the bond assets or in the rate of income generated by them, and

entitlement to the redemption payment may (but need not) be capable of being satisfied (whether or not at the option of the bond-issuer or the bond-holder) by the issue or transfer of shares or other securities.

purchase and resale arrangements,

diminishing shared ownership arrangements,

deposit arrangements,

profit share agency arrangements, or

investment bond arrangements.

apart from this section they would be alternative finance arrangements,

subsection (3) or (5) of section 147 of TIOPA 2010 (tax calculations to be based on arm's length, not actual, provision) requires the profits and losses of a person who is a party to the arrangements to be calculated for tax purposes as if the arm's length provision (within the meaning of that section) had been made or imposed rather than in accordance with the arrangements,