Part 6Relationships treated as loan relationships etc
Chapter 6Alternative finance arrangements
Power to extend this Chapter to other arrangements
521Power to extend this Chapter to other arrangements
1
The Treasury may by order amend the alternative finance provisions.
2
The amendments which may be made by such an order include—
a
the variation of provision already included in the alternative finance provisions, and
b
the introduction into those provisions of new provision relating to alternative finance arrangements.
3
In this section “alternative finance arrangements” means arrangements which in the Treasury's opinion—
a
equate in substance to a loan, deposit or other transaction of a kind that generally involves the payment of interest, but
b
achieve a similar effect without including provision for the payment of interest.
4
An order under subsection (1) may, in particular—
a
make provision of a kind similar to provision already made by the alternative finance provisions,
b
make other provision about the treatment for the purposes of the Corporation Tax Acts of arrangements to which the order applies,
c
make provision generally or only in relation to specified cases or circumstances,
d
make different provision for different cases or circumstances, and
e
make incidental, supplemental, consequential and transitional provision and savings.
5
An order making consequential provision under subsection (4)(e) may, in particular, include provision amending a provision of the Tax Acts.
6
In this section “the alternative finance provisions” means—
a
this Chapter,
b
section 209(6A) of ICTA (meaning of distribution),
c
section 411ZA of ICTA (no relief where deduction of relevant return under alternative finance arrangements disallowed), and
d
section 151F of TCGA 1992 (treatment of alternative finance arrangements).