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)