SCHEDULES
SCHEDULE 11Employment income provided through third parties: loans etc outstanding on 5 April 2019
PART 1Application of Part 7A of ITEPA 2003
Quasi-loans made in a depreciating currency
17
1
Paragraph 18 applies in relation to the quasi-loan if—
a
the quasi-loan currency is a currency other than sterling, and
b
it is reasonable to suppose that the main reason, or one of the main reasons, for the quasi-loan being made in that currency is that the quasi-loan currency is expected to depreciate during the quasi-loan period.
2
The “quasi-loan period”, in relation to a quasi-loan, is the period—
a
beginning at the time the quasi-loan is made, and
b
ending with the time by which, under the terms of the quasi-loan, the whole of the quasi-loan is to be repaid.
18
1
Where this paragraph applies in relation to the quasi-loan—
a
paragraphs 15 and 16 do not apply in relation to the quasi-loan, and
b
sub-paragraphs (2) to (5) apply for the purposes of calculating the amount of the quasi-loan that is outstanding at the time P is treated as taking the relevant step F1within paragraph 1.
2
The initial debt amount, in relation to the quasi-loan, is an amount equal to the total of—
a
the value in sterling, at the reference date, of the acquired debt, and
b
the value in sterling, at the reference date, of any additional debt.
3
The “reference date”—
a
in relation to a right within sub-paragraph (2)(a), means the date on which P acquires it, and
b
in relation to a right within sub-paragraph (2)(b), means the date on which P acquires it.
4
The repayment amount, in relation to the quasi-loan, is an amount equal to the total of—
a
the amount of the initial debt amount that has been repaid in sterling, and
b
where payments are made, in a currency other than sterling, by way of repayment of the initial debt amount, the amount equal to the sterling value of the payments.
5
The “sterling value” of a payment is its value in sterling on the date it is made.