Corporation Tax Act 2009 Schedule 2, paragraphs 74–75

Transitional rules for alternative finance arrangements

Paragraphs 74 and 75 set out the transitional provisions governing how the alternative finance arrangements rules in Chapter 6 of Part 6 apply to arrangements that were already in place before the relevant commencement dates.

• Diminishing shared ownership arrangements entered into before 1 April 2006 are entirely excluded from the alternative finance rules.
• Profit share agency arrangements entered into before 1 April 2006 are only caught if alternative finance return is payable on or after that date, in which case the loan is deemed to start on 1 April 2006 at the notional carrying value of the arrangement.
• Investment bond arrangements entered into before 1 April 2007 are only caught if alternative finance return is payable on or after that date, with the loan deemed to start on 1 April 2007 at the notional carrying value of the arrangement.
• For investment bonds disposed of after 6 April 2007, section 519(2) is treated as always having had effect for income tax and capital gains tax purposes, regardless of when the arrangements were entered into.