Corporation Tax Act 2009 section 519

Investment bond arrangements: other provisions

Section 519 sets out how investment bond arrangements interact with the tax regimes for securitisation companies, close companies, group relief, unit trust schemes, and offshore funds.

• A bond-issuer under investment bond arrangements is not treated as a securitisation company unless it qualifies as one through separate, non-investment-bond arrangements.
• For close company and group relief purposes, bond-holders are treated as loan creditors of the bond-issuer, and investment bond arrangements are disregarded when determining participator status and equity holder status.
• Investment bond arrangements do not constitute a unit trust scheme for corporation tax purposes.
• Investment bond arrangements do not constitute an offshore fund for corporation tax purposes.