[439 Exemption in respect of certain pre-13 May 2016 loan relationships]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[439  Exemption in respect of certain pre-13 May 2016 loan relationships]

[(1)     A loan relationship is a “qualifying old loan relationship” of a qualifying infrastructure company if—

(a)     the company entered into the loan relationship on or before 12 May 2016, and

(b)     as at that date, at least 80% of the total value of the company's future qualifying infrastructure receipts for the qualifying period was highly predictable by reference to qualifying public contracts,

but see subsection (8) for cases where a loan relationship is not a qualifying old loan relationship of the company.

(2)     For the purposes of this section “the qualifying period” means—

(a)     in a case where the loan relationship would cease to subsist at any time before 12 May 2026 (if any amendments of the loan relationship made on or after 12 May 2016 are ignored), the period beginning with 12 May 2016 and ending with that time, and

(b)     in any other case, the period of 10 years beginning with 12 May 2016.

(3)     For

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