SCHEDULES

SCHEDULE 5Avoidance involving financial arrangements

Shares treated as loan relationships

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1

Section 91A of FA 1996 (shares subject to outstanding third party obligations) is amended as follows.

2

In subsection (4) (debits in respect of certain transactions to be ignored), for “No debits are to be brought into account” substitute “ In determining those debits and credits there are to be left out of account amounts ”.

3

Insert at the end—

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In this section “share” does not include a share in a building society.

4

The amendment made by sub-paragraph (2) has effect in relation to accounting periods ending on or after 6th March 2007.

5

But, in relation to accounting periods beginning before that date, amounts are to be left out of account as a result of that amendment only if they relate to any time on or after that date.

6

The amendment made by sub-paragraph (3) has effect in relation to shares held on or after 6th March 2007.