Part 6Relationships treated as loan relationships etc
F1Chapter 2BTransferred income streams
486FIntroduction to Chapter
1
This Chapter provides for Part 5 to apply in relation to a company to which an income stream transfer is made (“ the transferee ”).
2
An “income stream transfer” is a transfer by a person (“ the transferor ”) to which either of the following provisions applies—
a
F2Chapter 1 of Part 16 of CTA 2010 (transfers of income streams by companies), or
b
Chapter 5A of Part 13 of ITA 2007 (transfers of income streams by individuals).
486GConsideration to be treated as loan relationship
1
For the purposes of this Part—
a
the consideration for the transfer of the right to relevant receipts is to be treated as a money debt which is owed to the transferee by the person by whom the relevant receipts fall to be paid, and
b
the transfer is to be treated as a transaction for the lending of money from which that debt is treated as arising.
2
For the meaning of “relevant receipts” see F3section 752(2) of CTA 2010 or section 809AZA(2) of ITA 2007.
Pt. 6 Ch. 2B inserted (with effect in accordance with Sch. 25 para. 10 of the amending Act) by Finance Act 2009 (c. 10), Sch. 25 para. 8(3)