[438A Application of section 438: certain creditors treated as qualifying infrastructure companies]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[438A  Application of section 438: certain creditors treated as qualifying infrastructure companies]

[(1)     This section applies where—

(a)     a company (“Câ€), at a time in the period mentioned in subsection (1) of section 438—

(i)     is a member of the worldwide group of which the qualifying infrastructure company mentioned in that subsection is a member, but

(ii)     is not a UK group company; and

(b)     C is a creditor in relation to an amount which—

(i)     is a relevant loan relationship debit (as defined in section 383) for the debtor company, or

(ii)     would be a relevant loan relationship debit if the debtor company were UK resident.

(2)     For the purposes of section 438, C is treated in relation to the amount mentioned in subsection (1)(b) (the “relevant loan amountâ€) as a qualifying infrastructure company if—

(a)     throughout the period mentioned in section 438(1), C—

(i)     meets the public infrastructure income test for the accounting period (see subsections (2) to (4) of section

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