Corporation Tax Act 2009 section 517

Treatment of bond-holder under investment bond arrangements

Section 517 clarifies how bond-holders and bond-issuers under investment bond arrangements are treated for Corporation Tax purposes, ensuring the bond-holder has no ownership interest in the underlying assets.

• The bond-holder is not treated as having any legal or beneficial interest in the bond assets for Corporation Tax purposes
• The bond-issuer is not treated as a trustee of the bond assets and does not act in a fiduciary or representative capacity
• All profits connected with the bond assets belong to the bond-issuer, not the bond-holder
• The bond-holder cannot claim capital allowances or other relief for capital expenditure relating to the bond assets