Taxation (International and Other Provisions) Act 2010 section 237

Instruments of alterable character

Section 237 defines what is meant by an "instrument of alterable character" for the purposes of identifying deduction schemes involving financial instruments whose terms can be changed.

• A financial instrument is of "alterable character" if its terms can be varied or it can be replaced by a different instrument
• This includes situations where any person has the power to bring about such a variation or replacement
• The section is the second in a group of seven sections that together define various types of "deduction scheme"
• These provisions help identify arrangements where the alterable nature of an instrument could be used to generate tax deductions