Corporation Tax Act 2009 section 477

Overview of Part

Section 477 provides an overview of Part 6 of the Corporation Tax Act 2009, which deals with arrangements and transactions that are treated, for some or all purposes, as loan relationships or as rights, payments or profits arising under loan relationships.

• Part 6 covers a wide range of financial arrangements that are treated as loan relationships for corporation tax purposes, even though they may not be conventional lending arrangements
• The topics covered include relevant non-lending relationships, disguised interest, transferred income streams, OEICs, unit trusts, offshore funds, building societies, registered societies, alternative finance arrangements, shares accounted for as liabilities, returns from partnerships, manufactured interest, repos, and investment life insurance contracts
• References to Part 5 (the main loan relationships part) should generally be read as also including references to Part 6, ensuring consistent tax treatment across both parts
• The priority rules in Part 5 (which determine how loan relationship provisions interact with other tax provisions) also apply to the matters covered by Part 6