SCHEDULES

SCHEDULE 2 U.K.Alternative finance arrangements

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

25 U.K.After section 564W insert—

“564X Treatment of principal under profit share agency arrangements

(1) The principal under profit share agency arrangements is not treated for the purposes of the Income Tax Acts as entitled to profits to which the agent is entitled in accordance with section 564F(1)(e).

(2) And the agent under such arrangements is treated for those purposes as entitled to those profits and the profits specified in section 564F(1)(d).

(3) In this section “the principal” and “the agent” are to be read in accordance with section 564F.”