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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Deemed loan relationships: holdings in investment funds: amounts treated as creditor loan relationships: anti-avoidance


In determining the credits and debits to be brought into account under CTA09/S490 for the purposes of fair value accounting amounts relating to any investment (for accounting periods ending on or after 6 March 2007) or liability (for accounting periods ending on or after 9 May 2007), certain amounts are left out of account. These are amounts relating to an investment or liability where the investment was made, or the liability was incurred, with the relevant avoidance intention or where any transaction or series of transactions was entered into in relation to the investment or liability with the relevant avoidance intention. By relevant avoidance intention we mean the intention of eliminating or reducing the loan relationships credits, or increasing the debits to be brought into account.

Amounts in respect of accounting periods prior to those specified above may only be left out of account if they actually relate to the accounting periods specified above.