SCHEDULE 24 Disguised Interest
Finance Act 2009 (2009 c 10) | Legislation

SCHEDULE 24 Disguised Interest

Section 48

Amendments of Part 6 of CTA 2009

1

Part 6 of CTA 2009 (relationships treated as loan relationships etc) is amended as follows.

2

(1)     Section 477(2) (overview of Part 6) is amended as follows.

(2)     After paragraph (a) insert—

“(aa)     Chapter 2A (disguised interest),â€.

(3)     For paragraph (f) substitute—

“(f)     Chapter 6A (shares accounted for as liabilities),â€.

3

After Chapter 2 insert—

“Chapter 2A
Disguised Interest
486´¡Ìý°¿±¹±ð°ù±¹¾±±ð·É

(1)     This Chapter provides for Part 5 to apply in relation to returns which are economically equivalent to interest (see section 486B).

(2)     For exclusions from this Chapter, see—

(a)     section 486C (return otherwise taxable),

(b)     section 486D (arrangement having no tax avoidance purpose), and

(c)     section 486E (excluded shares).

486B Disguised interest to be regarded as profit from loan relationship

(1)     Where a company is party to an arrangement which produces for the company a return in relation to any amount which is economically equivalent to interest, Part 5 applies as if the return were a profit arising to the company from a loan relationship.

(2)     For the purposes of this Chapter a return produced

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