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HMRC internal manual

Corporate Finance Manual

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HM Revenue & Customs
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Deemed loan relationships: disguised interest: repealed provisions

Disguised interest: repeal of the ‘shares as debt’ and other rules

As a result of the new legislation, the shares as debt rules have been repealed, with the repeals coming into force on 22 April 2009. See CFM42030 for what happens when shares cease to be ones to which the shares as debt rules apply.

A range of other provisions dealing with disguised interest have also been repealed. The most significant of these are:

  • Section 736C of ICTA (deemed interest: cash collateral under stock lending arrangement)
  • Section 736D of ICTA (quasi-stock lending arrangements)
  • Section 547 of CTA 2009 (repo under arrangement designed to produce quasi-interest)

These are referred to below as ‘repealed provisions’.