Corporation Tax Act 2009 section 73

Alternative finance arrangements entered into before certain dates

Section 73 sets out transitional rules that limit how the alternative finance arrangements regime applies to arrangements entered into before 6 April 2005, and explains how pre-existing deposit arrangements are brought into the loan relationships rules.

• The alternative finance arrangements rules in Chapter 6 of Part 6 do not apply at all to purchase and resale arrangements entered into before 6 April 2005.
• For deposit arrangements entered into before 6 April 2005, the rules only apply if alternative finance return is payable on or after that date — these are called "relevant deposit arrangements".
• Where a company is party to such pre-6 April 2005 deposit arrangements, the loan treated as existing under the loan relationships rules is deemed to have been made on 6 April 2005, with a principal amount equal to the notional carrying value of the related asset or liability.
• The notional carrying value is the amount that would have appeared in the company's accounts, prepared under generally accepted accounting practice, if a period of account had ended immediately before 6 April 2005.