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Contents

Legislation
Corporation Tax Act 2010

Crossheading Type 2 arrangements

  • Section 763 Type 2 finance arrangement defined
  • Section 764 Relevant change in relation to partnership
  • Section 765 Certain tax consequences not to have effect
  • Section 766 Deemed loan relationship
  1. Type 2 arrangements
  2. Relevant change in relation to partnership

Section 764 | Relevant change in relation to partnership

From legislation.gov.uk

(1)For the purposes of this Chapter there is a relevant change in relation to a partnership if condition A or condition B is met.

(2)Condition A is that in connection with the arrangement the lender or a person connected with the lender becomes a member of the partnership at any time.

(3)Condition B is that—

(a)in connection with the arrangement there is at any time a change in a member's share in the partnership's profits, and

(b)the member is the lender or a person connected with the lender or a person who in connection with the arrangement becomes at any time connected with the lender.

(4)An event occurs in connection with the arrangement if it occurs directly or indirectly in consequence of it or otherwise in connection with it.

(5)If there is a relevant change in relation to a partnership, a reference in this Chapter to the person involved in the change is—

(a)if it is condition A that is met, to the person who becomes a member of the partnership, and

(b)if it is condition B that is met, to the member of the partnership in whose share in the partnership's profits there is a change.

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