Deemed loan relationships: disguised interest: excluded shares: basic rules
Excluded shares: the basic rules
CTA09/486E(1) sets out the basic rule that the disguised interest rules will not apply in any ‘relevant accounting period’ where the return ‘involves only’ ‘relevant shares’.
Relevant accounting period
CTA09/486E(2) defines ‘relevant accounting period’ as:
- beginning when the holding company becomes party to the arrangement or, if later, when the arrangement begins to produce a return to the company;
- ending when the holding company ceases to be party to the arrangement or, if earlier, the end of the relevant accounting period.