Related Commentary  Related HMRC Manuals

521C(1)  This section applies to the share if–

(a)the share would be accounted for by the issuing company as a liability in accordance with generally accepted accounting practice,

(b)the share produces for the investing company a return in relation to any amount which is economically equivalent to interest,

(c)the issuing company and the investing company are not connected companies,

(d)the condition in subsection (4) is met,

(e)the share is not an excepted share (see section 521D), and

(f)the investing company holds the share for an unallowable purpose (see section 521E).

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