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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate finance: structured finance: relevant change for Condition A and B cases

Relevant change

Both Condition A and B cases require there to be a ‘relevant change’ in relation to the partnership membership. Section 764 provides that there is a relevant change in relation to the partnership membership for the purposes of sections 763 to 769 where, in connection with the arrangement, the lender (or connected person) is either admitted to the partnership or receives a revised share of its profits. In practice, the revised share will be an increased one so as to repay the additional capital contributed plus ‘interest’.