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Taxation (International and Other Provisions) Act 2010

Section 564E: Deposit arrangements

760.This section deals with an arrangement whereby deposits are made with a financial institution and payments are made to the depositor out of profits earned by the use of the money. It is based on section 49(1) of FA 2005. The corresponding rule for corporation tax is section 505 of CTA 2009.

761.The payments must equate to a return from an investment at interest. The return is treated as alternative finance return.

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