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Taxation (International and Other Provisions) Act 2010
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- UK Public General Acts
- 2010 c. 8
- SCHEDULE 2
- Part 1
- Paragraph 20
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20After section 564R insert—
“564STreatment 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.”
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