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HMRC internal manual

Corporate Finance Manual

Loan relationships: tax avoidance: overview: other anti-avoidance rules

Other tax avoidance rules

Apart from the ‘unallowable purposes’ rule and the arm’s length rules (CFM38010), there are a number of other rules, in the loan relationships legislation and elsewhere, intended to address avoidance schemes.

  • Artificial payments of interest - CTA09/S443 (CFM39020).
  • Connected parties deriving benefit from creditor relationships (CFM39035).
  • Reset bonds - CTA09/S454 (CFM39040).
  • Consideration not fully recognised by accounting practice - CTA09/S455 (CFM39080).
  • ‘Hybrid securities’ issued between connected companies (CFM37730).
  • The ‘disguised interest’ rules in CTA09/PT6/CH2A (CFM42000), which are a successor to the ‘shares as debt’ rules formerly in CT09/PT6/CH7 (CFM45000). Note that these rules take precedence over the arbitrage’ rules involving ‘hybrid securities F(No.2)A05/SCH3).
  • The ‘transfers of income streams’ rules in FA09/SCH25 (CFM77000).
  • ‘Late-paid’ interest (CFM35800).
  • Company migration (CFM33250).
  • ‘Structured finance arrangements’ or ‘factoring’ legislation (CFM73000).
  • Index-linked gilt-edged securities (CFM39100)
  • Derecognition (CFM39200)
  • Group mismatch schemes (CFM77500)