Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 564N: Alternative finance return under arrangements for trade or property business purposes

774.This section directs that, where a person is party to an alternative finance arrangement for the purposes of a trade or property business, then any alternative finance return paid is treated as an expense of that trade or business. It is based on section 51(3) to (5) of FA 2005.

775.Specific provision is made to permit the deductibility of the incidental costs of raising loan finance via alternative finance arrangements under section 58 of ITTOIA.

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