Income Tax Act 2007 section 835J

Persons acting under alternative finance arrangements

Section 835J prevents certain persons involved in alternative finance arrangements from being treated as the UK representative of a non-UK resident in relation to alternative finance return income.

• Where a non-UK resident receives income in the form of alternative finance return that falls within section 835E(2), special rules apply to limit who can be treated as their UK representative
• The counterparty to the alternative finance arrangements cannot be the UK representative of the non-UK resident in respect of that income
• Any other person acting for the non-UK resident in connection with those alternative finance arrangements is also excluded from being the UK representative
• Alternative finance return for these purposes means return arising under purchase and resale arrangements, diminishing shared ownership arrangements, or certain other qualifying alternative finance arrangements