Where a person (other than a company) becomes a party to an ‘arrangement’ which produces a return for that person which is ‘economically equivalent to interest’, in relation to any amount of money, that return, if not otherwise chargeable, is chargeable to income tax under ITTOIA 2005, s. 381A).

For these purposes, an ‘arrangement’ is widely defined to include any agreement, understanding, scheme, transaction or series of transactions, even if they are not legally enforceable (ITTOIA 2005, s. 381A(6)).

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