Taxation (International and Other Provisions) Act 2010 section 253

Exception for dealers

Section 253 provides an exception from the loan relationship receipt rules for certain dealers who would otherwise meet the conditions for being caught by the receipt scheme.

• This section carves out an exception for dealers who would otherwise fall within condition D of the receipt scheme conditions.
• Condition D is one of several conditions that determine whether a company's loan relationship income is subject to the receipt scheme rules.
• Dealers — typically banks and financial traders who hold loan relationships as part of their trading activities — are treated differently because their commercial circumstances justify exclusion.
• The exception recognises that dealers enter into loan relationships for genuine trading purposes rather than to exploit the tax rules the receipt scheme is designed to counteract.