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HMRC internal manual

Corporate Finance Manual

Deemed loan relationships: returns from partnerships: definitions for CTA09/S536, S537 and S538

Overview of legislation: definitions

This guidance applies to companies that have interests in partnerships up to 21 April 2009 

The following words or phrases appear in the legislation at CTA09/PT6/CH8 and are defined as follows:

Relevant arrangements

‘Relevant arrangements’ means:

  • Arrangements which are designed to produce a return for the company equivalent, in substance, to a return on the investment of money at a commercial rate of interest, and
  • The purpose or one of the main purposes of the arrangements is to secure a tax advantage.

Connected persons

‘Connected persons’ takes its meaning from CTA10/S1122.


‘Arrangements’ includes any agreement, understanding, scheme, transaction or series of transactions.

Tax advantage

‘Tax advantage’ has the meaning given to it be CTA10/S1139.

Due Share

‘Due share’ of profit or capital is the share of profit or capital that the company would have been allocated or entitled to had it been allocated or entitled to a share by reference to the proportion of total capital contributed by it.