Part 6 U.K.Relationships treated as loan relationships etc

[F1 Chapter 2B U.K.Transferred income streams

Textual Amendments

F1 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)

486F Introduction to Chapter U.K.

(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) [F2 Chapter 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).

Textual Amendments

F2 Words in s. 486F(2)(a) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 625 (with Sch. 2)

486G Consideration to be treated as loan relationship U.K.

(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 [F3 section 752(2) of CTA 2010] or section 809AZA(2) of ITA 2007.]

Textual Amendments

F3 Words in s. 486G(2) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 626 (with Sch. 2)