Income Tax Act 2007 section 564T

Treatment as securities

Section 564T ensures that investment bond arrangements are treated as securities for income tax purposes, so that existing tax rules for conventional securities apply equally to these alternative finance products.

  • Investment bond arrangements are classified as securities for the purposes of the Income Tax Acts, including the employment income provisions in ITEPA 2003
  • Any legislative reference to "redemption" of a security is read as a reference to making the redemption payment under the investment bond arrangement
  • Any legislative reference to "interest" on a security is read as a reference to the alternative finance return generated by the arrangement
  • The meaning of "redemption payment" is defined by reference to section 564G, which sets out the structure of investment bond arrangements

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