SCHEDULE 12 Trading Income Provided Through Third Parties: Loans etc Outstanding on 5 April 2019

SCHEDULE 12 Trading Income Provided Through Third Parties: Loans etc Outstanding on 5 April 2019

Section 35

Application of sections 23A to 23H of ITTOIA 2005 in relation to loans etc outstanding on 5 April 2019

1

(1)     A loan or quasi-loan in relation to which sub-paragraph (2) applies is to be treated [for the purposes of sections 23A to 23H of ITTOIA 2005 as a relevant benefit that arises immediately before the end of 5 April 2019].

(2)     This sub-paragraph applies in relation to a loan or a quasi-loan if—

(a)     the loan or quasi-loan was made—

(i)     on or after [9 December 2010], and

(ii)     before 6 April 2017, and

(b)     an amount of the loan or quasi-loan is outstanding immediately before the end of 5 April 2019.

(3)     Where section 23E of ITTOIA 2005 applies [and T has not made an election for the purposes of sub-paragraph (3A)] in relation to a relevant benefit which is a loan or quasi-loan in relation to which sub-paragraph (2) applies, section 23E has effect—

(a)     as if the “relevant benefit amount†were the amount of the loan or quasi-loan that is outstanding [at the time the relevant

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