[809BZC Payments treated as borrower's income]

[809BZC  Payments treated as borrower's income]

[(1)     This section applies if—

(a)     a type 1 finance arrangement would not have the relevant effect (ignoring section 809BZB(2)),

(b)     that arrangement would not have the corresponding corporation-tax effect (ignoring section 759(2) of CTA 2010),

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