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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
Updated
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Deemed loan relationships: shares with guaranteed returns (‘shares as debt’): contents

  1. CFM45010
    Deemed loan relationships: shares with guaranteed returns: introduction
  2. CFM45020
    Deemed loan relationships: shares with guaranteed returns: examples of avoidance schemes
  3. CFM45030
    Deemed loan relationships: shares with guaranteed returns: outline of legislation
  4. CFM45040
    Deemed loan relationships: shares with guaranteed returns: main sections of legislation
  5. CFM45050
    Deemed loan relationships: shares with guaranteed returns: outstanding third party obligations
  6. CFM45060
    Deemed loan relationships: shares with guaranteed returns: outstanding third party obligations: debits and credits
  7. CFM45070
    Deemed loan relationships: shares with guaranteed returns: outstanding third party obligations: meaning of outstanding third party obligations
  8. CFM45080
    Deemed loan relationships: shares with guaranteed returns: outstanding third party obligations: meaning of interest like investment
  9. CFM45090
    Deemed loan relationships: shares with guaranteed returns: outstanding third party obligations: comparison with commercial rate of interest
  10. CFM45100
    Deemed loan relationships: shares with guaranteed returns: outstanding third party obligations: repos and stock loans
  11. CFM45110
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares
  12. CFM45120
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: debits and credits
  13. CFM45130
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: meaning of non-qualifying shares
  14. CFM45140
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: repos and stock loans
  15. CFM45150
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the ‘increasing value condition’
  16. CFM45160
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: definition of income producing assets
  17. CFM45170
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the income producing assets test
  18. CFM45180
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the income producing assets test: groups
  19. CFM45190
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: application of the increasing value condition
  20. CFM45200
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the redemption return condition
  21. CFM45210
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the redemption return condition: meaning of excepted share
  22. CFM45220
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the redemption return condition: meaning of qualifying publicly issued shares
  23. CFM45230
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the redemption return condition: mirroring a public issue of shares
  24. CFM45240
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the redemption return condition: unallowable purposes test
  25. CFM45250
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the associated transactions condition
  26. CFM45260
    Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: the associated transactions condition: meaning of associated transaction
  27. CFM45270
    Deemed loan relationships: shares with guaranteed returns: beginning or ceasing to be within the rules
  28. CFM45280
    Deemed loan relationships: shares with guaranteed returns: shares changing ownership in a group
  29. CFM45290
    Deemed loan relationships: shares with guaranteed returns: 16 March 2005 transitional rules
  30. CFM45300
    Deemed loan relationships: shares with guaranteed returns: schemes unwound by 31 December 2005
  31. CFM45310
    Deemed loan relationships: shares with guaranteed returns: meaning of commercial rate of interest
  32. CFM45320
    Deemed loan relationships: shares with guaranteed returns: meaning of commercial rate of interest: simple commercial rate
  33. CFM45330
    Deemed loan relationships: shares with guaranteed returns: interaction with arbitrage rules and capital gains