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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate finance: structured finance: Sections 763 to 769

Overview of the operation of sections 763-769

Sections 763 to 769 closely resemble sections 758 to 762 both in scope and counteraction, but are targeted at the complex partnership case.

Section 763 sets out the conditions for an arrangement to be a structured finance arrangement in much the same way as section 758. Then, where these conditions are met, section 765 restores to the borrower any alienated income (or denies relief for any income expense). Finally, as with section 759, section 765 provides that any finance charge in the accounts is treated as interest.