Taxation (International and Other Provisions) Act 2010

40 After section 151S insert—

“Special rules for investment bond arrangements

151T Investment bond arrangements are qualifying corporate bonds

(1) For the purposes of section 117, investment bond arrangements are a corporate bond, issued on the date on which the arrangements are entered into, if each of conditions A to D is met.

(2) Condition A is that the capital is expressed in sterling.

(3) Condition B is that the arrangements do not include provision for the redemption payment to be in a currency other than sterling.

(4) Condition C is that entitlement to the redemption payment is not capable of conversion (directly or indirectly) into an entitlement to the issue of securities apart from other arrangements to which section 151N applies.

(5) Condition D is that the additional payments are not determined wholly or partly by reference to the value of the bond assets.

(6) Section 117(2) applies for the purposes of this section as it applies for the purposes of section 117(1).”