Part 16Factoring of income etc

Chapter 3Loan or credit transactions

778Certain payments treated as 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 F1Chapter 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 Corporation Tax Acts as if it were a payment of interest.