[486B Disguised interest to be regarded as profit from loan relationship]

[486B  Disguised interest to be regarded as profit from loan relationship]

[(1)     Where a company is party to an arrangement which produces for the company a return in relation to any amount which is economically equivalent to interest, Part 5 applies as if the return were a profit arising to the company from a loan relationship.

(2)     For the purposes of this Chapter a return produced for a company by an arrangement in relation to any amount is “economically equivalent to interest” if (and only if)—

(a)     it is reasonable to assume that it is a return by reference to the time value of that amount of money,

(b)     it is

Powered by Lexis+®

Popular documents