CFM44300 | Deemed loan relationships: alternative finance: other tax rules: distributions

Interactions with distributions legislation

Although an alternative finance return is dependent on the result of part of the financial institution’s business it is specifically excluded from being a distribution under CTA10/S1019.

Similarly, neither additional payments nor any part of the redemption payments (CFM44160) made to holders of alternative finance investment bonds can be a distribution under CTA10/Part 23, even though it might be argued that payment of the full amounts depends on the results of the issuing company’s business.