CFM45400 - Deemed loan relationships: returns from partnerships: contents

This guidance applies to companies that have interests in partnerships up to 21 April 2009. See CFM42000 for guidance on the disguised interest rules applicable to arrangements entered into on or after 22 April 2009

When CTA09/PT6/CH8 has effect

Finance Act 2008 introduced anti-avoidance provisions targeting schemes which used partnerships to convert what is economically interest into either capital gains or tax nothings.

The rules apply to returns arising to a company from interests in partnerships on or after 12 March 2008 (i.e. Budget Day).

1. CFM45410

   Returns from partnerships: introduction
2. CFM45420

   Returns from partnerships: avoidance schemes: examples
3. CFM45430

   Returns from partnerships: main sections of legislation
4. CFM45440

   Returns from partnerships: conditions for CTA09/S536
5. CFM45450

   Returns from partnerships: definitions for CTA09/S536, S537 and S538
6. CFM45460

   Returns from partnerships: effect of CTA09/S536