Corporation Tax Act 2009 Explanatory Notes

Section 499: Industrial and provident society payments treated as interest under loan relationship

1385.This section treats certain payments by an industrial and provident society and agricultural or fishing co-operatives as payments of interest on a loan relationship. It is based on section 486(1), (4), (9) and (12) of ICTA. The corresponding provision for income tax is section 379 of ITTOIA.

1386.Subsection (2) treats dividends, bonuses and other sums payable on shareholdings held for the purposes of a trade or for other purposes as if that shareholding were a loan relationship so held. See Change 62 in Annex 1.

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