SCHEDULES

SCHEDULE 3Qualifying scheme

Part 3Schemes involving hybrid effect

Debt instruments treated as equity

8

1

A scheme satisfies the requirements of this paragraph if it includes a debt instrument issued by a company that is treated as equity in the company under generally accepted accounting practice.

2

For the purposes of this paragraph, a debt instrument is an instrument issued by a company that represents a loan relationship of the company or, if the company were a company resident in the United Kingdom, would represent a loan relationship of the company.