8(1)Part 6 of CTA 2009 (relationships treated as loan relationships etc) is amended as follows.U.K.
(2)In section 477(2) (overview of Part 6), after paragraph (aa) (inserted by Schedule 24) insert—
“(ab)Chapter 2B (transferred income streams),”.
(3)After Chapter 2A (inserted by Schedule 24) insert—
(1)This Chapter provides for Part 5 to apply in relation to a company to which an income stream transfer is made (“the transferee”).
(2)An “income stream transfer” is a transfer by a person (“the transferor”) to which either of the following provisions applies—
(a)Part 1 of Schedule 25 to FA 2009 (transfers of income streams by companies), or
(b)Chapter 5A of Part 13 of ITA 2007 (transfers of income streams by individuals).
(1)For the purposes of this Part—
(a)the consideration for the transfer of the right to relevant receipts is to be treated as a money debt which is owed to the transferee by the person by whom the relevant receipts fall to be paid, and
(b)the transfer is to be treated as a transaction for the lending of money from which that debt is treated as arising.
(2)For the meaning of “relevant receipts” see paragraph 1(2) of Schedule 25 to FA 2009 or section 809AZA(2) of ITA 2007.”