Skip to content
Solved
SearchBrowse
Sign in

Contents

Legislation
Corporation Tax Act 2009

Crossheading Treatment for other tax purposes

  • Section 514 Exclusion of alternative finance return from consideration for sale of assets
  • Section 515 Diminishing shared ownership arrangements : further provision
  • Section 515A Diminishing shared ownership arrangements: further provision in respect of refinancing
  • Section 516 Treatment of principal under profit sharing agency arrangements
  • Section 517 Treatment of bond-holder under investment bond arrangements
  • Section 518 Investment bond arrangements: treatment as securities
  • Section 519 Investment bond arrangements: other provisions
  • Section 520 Provision not at arm's length: non-deductibility of relevant return
  1. Treatment for other tax purposes
  2. Investment bond arrangements: other provisions

Section 519 | Investment bond arrangements: other provisions

From legislation.gov.uk

(1)A bond-issuer is not a securitisation company for the purposes of section 83 of FA 2005 (application of accounting standards to securitisation companies) unless it is one as a result of arrangements which are not investment bond arrangements.

(2)For the purposes of sections 453 and 454 of CTA 2010 (definitions related to close companies)—

(a)a bond-holder is a loan creditor in respect of the bond-issuer, and

(b)investment bond arrangements must be ignored in the application of section 454(2)(e) of CTA 2010.

(3)For the purposes of Chapter 6 of Part 5 of CTA 2010 (group relief)—

(a)a bond-holder is a loan creditor in respect of the bond-issuer, and

(b)condition C in section 162(4) of CTA 2010 must be ignored in determining whether a person is an equity holder as a result of investment bond arrangements.

(4)Investment bond arrangements are not—

(a)a unit trust scheme for the purposes of section 1119 of CTA 2010, or

(b)an offshore fund for the purposes of section 354 of TIOPA 2010 so far as relating to corporation tax.

PreviousNext
PrivacyTerms