Part 13Tax avoidance

F1Chapter 5CLoan or credit transactions

809CZALoan or credit transaction defined

(1)

This section defines a loan or credit transaction for the purposes of sections 809CZB and 809CZC.

(2)

A transaction is a loan or credit transaction if it is—

(a)

effected with reference to the lending of money or the varying of the terms on which money is lent, or

(b)

effected with a view to enabling or facilitating an arrangement concerning the lending of money or the varying of the terms on which money is lent.

(3)

A transaction is a loan or credit transaction if it is—

(a)

effected with reference to the giving of credit or the varying of the terms on which credit is given, or

(b)

effected with a view to enabling or facilitating an arrangement concerning the giving of credit or the varying of the terms on which credit is given.

(4)

Subsection (2) has effect whether the transaction is effected—

(a)

between the lender and borrower,

(b)

between either of them and a person connected with the other, or

(c)

between a person connected with one and a person connected with the other.

(5)

Subsection (3) has effect whether the transaction is effected—

(a)

between the creditor and debtor,

(b)

between either of them and a person connected with the other, or

(c)

between a person connected with one and a person connected with the other.