F1Part 10AAlternative finance arrangements
F2Special rules for investment bond arrangements
S. 564R and cross-heading inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 2 para. 19 (with Sch. 9 paras. 1-9, 22)
C1564SF3Treatment of bond-holder and bond-issuer
1
This section applies for the purposes of the Income Tax Acts and irrespective of the position for other purposes.
2
The bond-holder under investment bond arrangements is not treated as having a legal or beneficial interest in the bond assets.
3
The bond-issuer under such arrangements is not treated as a trustee of the bond assets.
4
Profits accruing to the bond-issuer in connection with the bond assets are profits of the bond-issuer and not of the bond-holder (and do not arise to the bond-issuer in a fiduciary or representative capacity).
5
Payments made by the bond-issuer by way of redemption payment or additional payment are not made in a fiduciary or representative capacity.
6
The bond-holder is not entitled to relief for capital expenditure in connection with the bond assets.
7
Expressions used in this section have the same meaning as in section 564G.
Pt. 10A inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 2 para. 2 (with Sch. 9 paras. 1-9, 22)