SCHEDULES

SCHEDULE 7U.K.Avoidance involving financial arrangements

Disposals and acquisitions of company loan relationships with or without interestU.K.

5(1)Section 807A of ICTA is amended as follows.U.K.

(2)After subsection (2A) (exclusion of certain tax) insert—

(2B)Where, in the case of any share, section 91A or 91B of the Finance Act 1996 (shares treated as loan relationships) applies in relation to a company for an accounting period, this section has effect—

(a)in relation to a distribution in respect of the share as it has effect in relation to interest under a loan relationship, and

(b)in relation to a distribution accruing in respect of the share at a time when the company does not (within the meaning of the section in question) hold the share as it applies in relation to interest accruing under a loan relationship at a time when the company is not a party to the loan relationship..

(3)The amendment made by this paragraph has effect in relation to shares held by a company on or after 16th March 2005.