[809BZB Certain tax consequences not to have effect]

[809BZB  Certain tax consequences not to have effect]

[(1)     This section applies if a type 1 finance arrangement would have the relevant effect (ignoring this section).

(2)     The arrangement is not to have that effect.

(3)     The relevant effect is that—

(a)     an amount of income on which the borrower or a person connected with the borrower

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