Regulation 28 | Loans other than participating loans
From legislation.gov.uk
(1)No liability to tax arises under regulation 17 if the asset is a loan which is not a participating loan.
(2)For the purposes of paragraph (1) a “participating loan” means a loan where the amount payable on redemption exceeds the issue price by an amount which is determined in whole or in part by reference to the income of the non-reporting fund.