Schedules

Schedule 3Corporate interest restriction etc.

Part 1Amendments to TIOPA 2010

17Partnerships and other transparent entities

In section 447 (partnerships and other transparent entities), for subsection (6) substitute—

6

For the purposes of this section an entity is “transparent” if—

a

it is not chargeable to corporation tax or income tax as a person (ignoring any exemptions), or

b

it is a collective investment vehicle which is “transparent for income tax purposes” for the purposes of paragraph 8 of Schedule 5AAA to TCGA 1992 (see paragraph 8(7) of that Schedule).