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HMRC internal manual

Corporate Finance Manual

Deemed loan relationships: disguised interest: meaning of ‘arrangement’


Meaning of arrangement

An arrangement, for the purposes of the disguised interest principle as set out in CTA09/486B(1), is defined at CTA09/486B(9) as including:

‘…any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).’

This is a wide-ranging definition that is intended to capture any type of arrangement under which disguised interest type returns could be obtained.

There is a specific exclusion for arrangements that constitute a finance lease for the purposes of CAA01/S219. This ensures that all such arrangements continue to be taxed according to current rules (and in particular that leases that are not long funding leases within the meaning of CAA01/S70G are not brought within the scope of the legislation). Operating leases, by contrast, are not within the scope of the legislation at all.