Income Tax Act 2007 section 564A

Introduction

Section 564A introduces the alternative finance arrangements regime, setting out the types of arrangement covered and signposting the key definitions and rules that apply for income tax purposes.

• Alternative finance arrangements encompass five types: purchase and resale, diminishing shared ownership, deposit, profit share agency, and investment bond arrangements
• The alternative finance return generated by these arrangements is treated as interest for certain income tax purposes, including deduction of tax at source
• Special rules apply to investment bond arrangements, covering matters such as discount treatment and ensuring they are not classified as unit trust schemes or offshore funds
• The Treasury has power to extend the alternative finance regime to other types of arrangement by statutory order