Related Commentary  Related HMRC Manuals

486B(1)  Where a company is party to an arrangement which produces for the company a return in relation to any amount which is economically equivalent to interest, Part 5 applies as if the return were a profit arising to the company from a loan relationship.

486B(2)  For the purposes of this Chapter a return produced for a company by an arrangement in relation to any amount is “economically equivalent to interest” if (and only if)–

(a)it is reasonable to assume that it is a return by reference to the time value of that amount of money,

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