Taxation (International and Other Provisions) Act 2010

This section has no associated Explanatory Notes

37U.K.After section 151P insert—

151QPurchase and resale arrangements where return in foreign currency

(1)If, in the case of purchase and resale arrangements, alternative finance return is paid in a currency other than sterling—

(a)by or to a person other than a company, and

(b)otherwise than for the purposes of a trade, profession or vocation or a property business,

subsections (2) and (3) apply as respects that person.

(2)The amount of the excess referred to in section 151P(2) and (5)(b) and the appropriate amount for the purposes of section 151P(3) and (4) are to be calculated in that other currency.

(3)The amount of each payment of alternative finance return is to be translated into sterling at a spot rate of exchange for the day on which the payment is made.