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HMRC internal manual

Corporate Finance Manual

Deemed loan relationships: alternative finance: Contents

  1. CFM44010
    Alternative finance: overview
  2. CFM44020
    Alternative finance: types of arrangement
  3. CFM44030
    Alternative finance: ‘financial institution’
  4. CFM44040
    Alternative finance: treatment as loan relationships
  5. CFM44050
    Alternative finance: purchase and resale arrangements: conditions
  6. CFM44060
    Alternative finance: purchase and resale arrangements: tax treatment
  7. CFM44070
    Alternative finance: diminishing shared ownership arrangements
  8. CFM44080
    Alternative finance: diminishing shared ownership arrangements: tax treatment
  9. CFM44090
    Alternative finance: deposit arrangements
  10. CFM44100
    Alternative finance: profit share agency arrangements
  11. CFM44110
    Alternative finance: profit share agency arrangements: example
  12. CFM44120
    Alternative finance: investment bond arrangements
  13. CFM44130
    Alternative finance: investment bond arrangements: example
  14. CFM44140
    Alternative finance: investment bond arrangements: conditions
  15. CFM44150
    Alternative finance: investment bond arrangements: conditions: bond assets
  16. CFM44160
    Alternative finance: investment bond arrangements: conditions: payments to bond-holders
  17. CFM44170
    Alternative finance: investment bond arrangements: conditions: convertible arrangements
  18. CFM44180
    Alternative finance: investment bond arrangements: conditions: discounts
  19. CFM44190
    Alternative finance: investment bond arrangements: conditions: exclusion of ‘profit-sharing’ arrangements
  20. CFM44200
    Alternative finance: investment bond arrangements: conditions: reasonable commercial return
  21. CFM44210
    Alternative finance: investment bond arrangements: conditions: accounting test
  22. CFM44220
    Alternative finance: investment bond arrangements: conditions: listing on a recognised stock exchange
  23. CFM44230
    Alternative finance: investment bond arrangements: tax treatment
  24. CFM44240
    Alternative finance: investment bond arrangements: tax treatment of ‘bond assets’
  25. CFM44250
    Alternative finance: investment bond arrangements: tax treatment of ‘bond assets’ as securities
  26. CFM44260
    Alternative finance: investment bond arrangements: tax treatment: ‘asset-backed’ securitisation arrangements
  27. CFM44270
    Alternative finance: transitional rules
  28. CFM44280
    Alternative finance: other tax rules: treatment of non-residents
  29. CFM44290
    Alternative finance: other tax rules: capital allowances and capital gains
  30. CFM44300
    Loan relationships: alternative finance: other tax rules: distributions
  31. CFM44310
    Alternative finance: other tax rules: deduction of tax
  32. CFM44320
    Alternative finance: other tax rules: transfer pricing
  33. CFM44330
    Alternative finance: other tax rules: beneficial loans to employees