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).
CFM45410Returns from partnerships: introduction
CFM45420Returns from partnerships: avoidance schemes: examples
CFM45430Returns from partnerships: main sections of legislation
CFM45440Returns from partnerships: conditions for CTA09/S536
CFM45450Returns from partnerships: definitions for CTA09/S536, S537 and S538
CFM45460Returns from partnerships: effect of CTA09/S536