Corporation Tax Act 2009 (c. 4)

Valid from 01/04/2009

Part 6 U.K. Relationships treated as loan relationships etc

Chapter 6 U.K. Alternative finance arrangements

Treatment for other tax purposes U.K.

519 Investment bond arrangements: other provisions U.K.

(1) A bond-issuer is not a securitisation company for the purposes of section 83 of FA 2005 (application of accounting standards to securitisation companies) unless it is one as a result of arrangements which are not investment bond arrangements.

(2) For the purposes of section 417 of ICTA (close companies)—

(a) a bond-holder is a loan creditor in respect of the bond-issuer, and

(b) investment bond arrangements must be ignored in the application of section 417(1)(d) of that Act.

(3) For the purposes of Schedule 18 to ICTA (group relief)—

(a) a bond-holder is a loan creditor in respect of the bond-issuer, and

(b) paragraph 1(5)(b) of that Schedule must be ignored in determining whether a person is an equity holder as a result of investment bond arrangements.