Part 6Relationships treated as loan relationships etc

Chapter 6Alternative finance arrangements

Treatment for other tax purposes

519Investment bond arrangements: other provisions

(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 F1sections 453 and 454 of CTA 2010 (definitions related to 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 F2section 454(2)(e) of CTA 2010.

(3)

For the purposes of F3Chapter 6 of Part 5 of CTA 2010 (group relief)—

(a)

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

(b)

F4condition C in section 162(4) of CTA 2010 must be ignored in determining whether a person is an equity holder as a result of investment bond arrangements.

F5(4)

Investment bond arrangements are not—

(a)

a unit trust scheme for the purposes of section 1119 of CTA 2010, or

(b)

an offshore fund for the purposes of section 354 of TIOPA 2010 so far as relating to corporation tax.