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HMRC internal manual

Corporate Finance Manual

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).