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Legislation
Corporation Tax Act 2009

Crossheading Deeply discounted securities: connected companies and close companies

  • Section 406 Introduction
  • Section 407 Postponement until redemption of debits for connected companies' deeply discounted securities
  • Section 408 Companies connected for section 407
  • Section 409 Postponement until redemption of debits for close companies' deeply discounted securities
  • Section 410 Exceptions to section 409
  • Section 411 Interpretation of section 409
  • Section 412 Persons indirectly standing in the position of creditor
  1. Deeply discounted securities: connected companies and close companies
  2. Persons indirectly standing in the position of creditor

Section 412 | Persons indirectly standing in the position of creditor

From legislation.gov.uk

(1)For the purposes of sections 407(1)(b) and 409 a person is treated as standing in the position of a creditor if the person indirectly stands in that position by reference to a series of loan relationships or relevant money debts.

(2)If a company (“C”) is so treated for the purposes of section 407(1)(b), the reference in section 407(1)(e) to the corresponding creditor relationship is a reference to C's creditor relationship.

(3)If a person (“P”) is so treated for the purposes of section 409, the reference in section 410(2)(b) to the corresponding creditor relationship is a reference to P's creditor relationship.

(4)In subsection (1) “relevant money debt” means a money debt which would be a loan relationship if a company directly stood in the position of creditor or debtor.

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