Taxation (International and Other Provisions) Act 2010 (c. 8)

SCHEDULES

SCHEDULE 2 U.K. Alternative finance arrangements

Part 1 U.K. New Part 10A of ITA 2007

15 U.K. After section 564M insert—

“564N Alternative finance return under arrangements for trade or property business purposes

(1) This section applies so far as a person is a party to alternative finance arrangements for the purposes of—

(a) a trade, profession or vocation carried on by that person, or

(b) a property business of that person.

(2) Alternative finance return paid by that person is treated as an expense of the trade, profession, vocation or business.

(3) In section 58 of ITTOIA 2005—

(a) references to a loan include references to alternative finance arrangements, and

(b) references to interest include references to alternative finance return.”