Part 13Tax avoidance
F1Chapter 5ATransfers of income streams
F2809AZEException: transfer by way of security
(1)
This Chapter does not apply if—
(a)
the consideration for the transfer is the advance under a type 1 finance arrangement, and
(b)
the transferor is, or is a member of a partnership which is, the borrower in relation to the arrangement.
(2)
This Chapter does not apply if—
(a)
the consideration for the transfer is the advance under a type 2 finance arrangement or a type 3 finance arrangement, and
(b)
the transferor is a member of the partnership which receives that advance under the arrangement.
(3)
In this section—
“type 1 finance arrangement” has the meaning given for the purposes of Chapter 5B by section 809BZA,
“type 2 finance arrangement” has the meaning given for the purposes of Chapter 5B by section 809BZF, and
“type 3 finance arrangement” has the meaning given for the purposes of Chapter 5B by section 809BZJ.