Valid from 01/04/2009

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

Chapter 8 U.K. Returns from partnerships

536 Introduction to Chapter U.K.

(1) This Chapter applies if a company is a party to certain arrangements involving a firm of which it is a member.

(2) Under the following provisions of this Chapter the return designed to be produced for the company by the arrangements is treated as a profit from a loan relationship for the purposes of Part 5—

(a) section 537(3) (payments in return for capital contribution to partnership), and

(b) section 538(3) (change of partnership shares).

(3) In this Chapter “arrangements” includes any scheme, agreement, understanding, transaction or series of transactions.