Exclusions: relevant repaymentsU.K.
8U.K.After section 554R insert—
“554RAExclusions: relevant repayments
(1)This section applies (subject to subsection (5)) if—
(a)a right to repayment of principal under a relevant loan (the “repayment right”) is held by or on behalf of a person (“P”), and
(b)on or after 9 December 2010, a sum of money (the “repayment sum”) is acquired by or on behalf of P by way of repayment of principal under the relevant loan.
(2)In this section “relevant loan” means a loan made on or after 6 April 1999.
(3)Subsection (4) applies if—
(a)on its acquisition, the repayment sum is the subject of a relevant step within section 554B taken by P, or
(b)for the sole purpose of the acquisition, the making of the payment of the repayment sum is a relevant step within section 554C(1)(a).
(4)Chapter 2 does not apply by reason of the relevant step if, on its acquisition, the repayment sum is held by or on behalf of P on the same basis as that on which the repayment right was held by or on behalf of P immediately before the acquisition.
(5)This section does not apply where there is any connection (direct or indirect) between the acquisition by or on behalf of P of the repayment sum and a tax avoidance arrangement (other than the arrangement under which the relevant loan was made).”