Deemed loan relationships: returns from partnerships: main sections of legislation
Overview of legislation
This guidance applies to companies that have interests in partnerships up to 21 April 2009
CTA09/S537 deals with ‘relevant arrangements’ under which a company obtains a return by acquiring a partnership interest for an amount equal to its discounted future value. This is intended to deal with Scheme 1 as set out in CFM45420.
CTA09/S538 deals with schemes where companies invest money in the form of capital contributions, initially receiving a share of the partnership profits smaller than would be received by reference to that contribution but with a compensating greater entitlement to capital of that partnership later on. This is intended to deal with Scheme 2 as set out in CFM45420.