Section 486G | Consideration to be treated as loan relationship
From legislation.gov.uk
(1)For the purposes of this Part—
(a)the consideration for the transfer of the right to relevant receipts is to be treated as a money debt which is owed to the transferee by the person by whom the relevant receipts fall to be paid, and
(b)the transfer is to be treated as a transaction for the lending of money from which that debt is treated as arising.
(2)For the meaning of “relevant receipts” see section 752(2) of CTA 2010 or section 809AZA(2) of ITA 2007.