Part 13Tax avoidance
F1Chapter 5CLoan or credit transactions
Annotations:
Amendments (Textual)
809CZBCertain payments treated as yearly interest
1
This section applies if a loan or credit transaction provides for a payment which is not interest but is—
a
an annuity or other annual payment falling within Part 5 of ITTOIA 2005 and chargeable to income tax otherwise than as relevant foreign income, or
b
an annuity or other annual payment which is from a source in the United Kingdom and chargeable to corporation tax under F2Chapter 7 of Part 10 of CTA 2009 (annual payments not otherwise charged) or regulation 15 of the Unauthorised Unit Trusts (Tax) Regulations 2013.
2
The payment must be treated for the purposes of the Income Tax Acts as if it were a payment of yearly interest (see, in particular, section 874).
Pt. 13 Ch. 5C inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 5 para. 7 (with Sch. 9 paras. 1-9, 22)