Part 3 Denial of Relief for Contributions Paid on or After 22 February 2012

Part 3 Denial of Relief for Contributions Paid on or After 22 February 2012

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In Chapter 4 of Part 4 of FA 2004 (registered pension schemes: tax reliefs and exemptions) after section 196A insert—

“196B Employer asset-backed contributions: denial of relief (1)

(1)     An employer (“Eâ€) is not to be given relief in respect of a contribution (“E's contributionâ€) paid by E under a registered pension scheme if conditions A, B and C are met.

(2)     Condition A is that—

(a)     under an arrangement (“the asset-backed arrangementâ€)—

(i)     a person (“the borrowerâ€) receives money or another asset (“the advanceâ€) from another person (“the lenderâ€),

(ii)     the borrower, or a person connected with the borrower, makes a disposal of an asset (“the securityâ€) to or for the benefit of the lender or a person connected with the lender, and

(iii)     the lender, or a person connected with the lender, is entitled to payments in respect of the security,

(b)     the borrower is E or a person connected with E, and

(c)     the advance is (wholly or partly) paid or provided by the lender out of E's contribution (directly or indirectly),

and the case is not one in relation

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