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’ 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’ takes its meaning from CTA10/S1122.
‘Arrangements’ includes any agreement, understanding, scheme, transaction or series of transactions.
‘Tax advantage’ has the meaning given to it be CTA10/S1139.
‘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.