Corporation Tax Act 2009 section 469

Creditors who are financial traders

Section 469 sets out the conditions that must be met for a financial trader acting as creditor to be exempt from the connected companies rules when buying and selling debt instruments of connected companies in the normal course of its trading activities.

• The creditor must buy or sell debt assets as an integral part of a trade it carries on in the accounting period, and must have acquired the specific asset in the course of those trading activities.
• The debt asset must either be listed on a recognised stock exchange at the end of the period, or be a security that must be redeemed within 12 months of its issue.
• At some point during the period, assets of the same kind must be beneficially owned by persons other than the creditor itself.
• For no more than 3 months in total during the period may connected companies beneficially own the equivalent of 30% or more of assets of the same kind.