Part 10AAlternative finance arrangements
Special rules for investment bond arrangements
F1564STreatment 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.