Corporation Tax Act 2009 section 509

Application of Part 5: general

Section 509 establishes that alternative finance arrangements entered into by a company are treated as loan relationships for the purposes of the corporation tax rules in Part 5.

• Where a company is party to alternative finance arrangements, Part 5 (the loan relationships rules) applies as though those arrangements were a loan relationship of that company.
• All references to loan relationships throughout the Corporation Tax Acts are to be read as including references to such alternative finance arrangements.
• This treatment covers all five types of alternative finance arrangements recognised in this chapter.
• Further detail on how Part 5 applies to each specific type of alternative finance arrangement is provided separately in section 510.