Corporation Tax Act 2010 (c. 4)

Part 16 U.K. Factoring of income etc

Chapter 3 U.K. Loan or credit transactions

778 Certain payments treated as interest U.K.

(1) This section applies if a loan or credit transaction provides for a payment which is not interest but is—

(a) an annuity or other annual payment falling within Part 5 of ITTOIA 2005 and chargeable to income tax otherwise than as relevant foreign income, or

(b) an annuity or other annual payment which is from a source in the United Kingdom and chargeable to corporation tax under [F1 Chapter 7 of Part 10 of CTA 2009 (annual payments not otherwise charged) or regulation 15 of the Unauthorised Unit Trusts (Tax) Regulations 2013.]

(2) The payment must be treated for the purposes of the Corporation Tax Acts as if it were a payment of interest.

Textual Amendments

F1 Words in s. 778(1)(b) substituted (6.4.2014) by The Unauthorised Unit Trusts (Tax) Regulations 2013 (S.I. 2013/2819), regs. 1(3), 39(5) (with reg. 32)