Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 809BZH: Certain tax consequences not to have effect

1143.This section disapplies certain tax consequences of a type 2 finance arrangement if certain conditions are met. It is based on sections 774D(1) to (4) and 774G(2) of ICTA.

1144.Under subsections (1) and (2), if – but for this section – a relevant change in relation to the partnership would have the “relevant effect”, then it does not.

1145.Subsection (3) defines the “relevant effect”. It specifies three alternative effects.

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