Part 2Income tax, corporation tax and capital gains tax
Chapter 5Alternative finance arrangements
Treatment of alternative finance arrangements
51Treatment of alternative finance arrangements: persons other than companies
1
Alternative finance return or profit share return is to be treated for the purposes of ITTOIA 2005 as if it were interest.
2
Sections 353 to 368 of ICTA (relief for payments of interest) have effect as if—
a
arrangements falling within section 47 involved the making of a loan, and
b
alternative finance return were interest;
and section 366 (information) shall have effect accordingly.
3
Subsections (4) and (5) apply to the extent that a person other than a company is a party to alternative finance arrangements for the purposes of a trade, profession or vocation carried on by him or for the purposes of a property business of his.
4
Alternative finance return or profit share return paid by him is to be treated as an expense of the trade, profession or vocation or of the property business.
5
Section 58 of ITTOIA 2005 (incidental costs of obtaining finance) has effect as if—
a
references to a loan included references to alternative finance arrangements, and
b
references to interest included references to alternative finance return or profit share return.