SCHEDULES

SCHEDULE 24U.K.Disguised interest

CommencementU.K.

15(1)This paragraph applies where—U.K.

(a)Chapter 7 of Part 6 of CTA 2009 applies in relation to a share held by a company immediately before 22 April 2009 by reason of the redemption return condition being met (see section 529 of that Act) (or would so apply but for the share not being designed to produce a return which equates in substance to the return on an investment of money at a commercial rate of interest), and

(b)section 521B of CTA 2009 applies in relation to the share and the company on 22 April 2009.

(2)Part 5 of CTA 2009 applies as if the company had acquired the share on 22 April 2009 for an amount equal to the notional carrying value of the share on that date.

(3)In sub-paragraph (2) “notional carrying value” has the same meaning as in section 521F(2) of CTA 2009 (see subsection (3) of that section).

(4)Section 521F of CTA 2009 does not apply by virtue of the coming into force of section 521B of that Act.