Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
Corporate Finance Manual

CFM44000 · Deemed loan relationships: alternative finance

  • CFM44010 · Overview
  • CFM44020 · Types of arrangement
  • CFM44030 · 'financial institution'
  • CFM44035 · Regulated electronic system facilitated arrangements and home purchase plan providers
  • CFM44040 · Treatment as loan relationships
  • CFM44050 · Purchase and resale arrangements
  • CFM44060 · Purchase and resale arrangements: tax treatment
  • CFM44070 · Diminishing shared ownership arrangements
  • CFM44080 · Diminishing shared ownership arrangements: tax treatment
  • CFM44090 · Deposit arrangements
  • CFM44100 · Profit share agency arrangements
  • CFM44110 · Example of profit share agency arrangements
  • CFM44120 · Investment bond arrangements
  • CFM44130 · Investment bond arrangements: example
  • CFM44140 · Investment bond arrangements: conditions
  • CFM44150 · Investment bond arrangements: conditions: bond assets
  • CFM44160 · Investment bond arrangements: conditions: payments to bond-holders
  • CFM44170 · Investment bond arrangements: conditions: convertible arrangements
  • CFM44180 · Investment bond arrangements: conditions: discounts
  • CFM44190 · Investment bond arrangements: conditions: exclusion of ‘profit-sharing’ arrangements
  • CFM44200 · Investment bond arrangements: conditions: reasonable commercial return
  • CFM44210 · Investment bond arrangements: conditions: accounting test
  • CFM44220 · Investment bond arrangements: conditions: listing on a recognised stock exchange
  • CFM44230 · Investment bond arrangements: tax treatment
  • CFM44240 · Investment bond arrangements: tax treatment of ‘bond assets’
  • CFM44250 · Investment bond arrangements: tax treatment of ‘bond assets’ as securities
  • CFM44260 · Investment bond arrangements: ‘asset-backed’ securitisation arrangements
  • CFM44270 · Transitional rules
  • CFM44280 · Other tax rules: treatment of non-residents
  • CFM44290 · Other tax rules: capital allowances and capital gains
  • CFM44300 · Other tax rules: distributions
  • CFM44310 · Other tax rules: deduction of tax
  • CFM44320 · Transfer pricing
  • CFM44330 · Beneficial loans for employees
  1. Deemed loan relationships: alternative finance: Contents
  2. Deemed loan relationships: alternative finance: investment bond arrangements: conditions: convertible arrangements

CFM44170 | Deemed loan relationships: alternative finance: investment bond arrangements: conditions: convertible arrangements

From HM Revenue & Customs · Corporate Finance Manual

Convertible or exchangeable sukuk

Just as the issue terms of conventional bonds may provide for them to be converted into shares of the issuing company on maturity, or exchanged for shares in some other company, alternative finance investment bonds may be convertible or exchangeable. (Since the issuing company is frequently a special purpose vehicle, ‘exchangeables’ are more common than ‘convertibles’). CTA09/S507(2)(i) specifically provides that entitlement to the redemption payment may be satisfied by the issue or transfer of shares or other securities.

PreviousNext
PrivacyTerms