[CFM45160] Deemed loan relationships: shares with guaranteed returns: non-qualifying shares: definition of income producing assets
Income producing assets test: definitions
This guidance applies to companies that hold shares up to 21 April 2009
The ‘income producing assets’ test provides a let out from S527. S527(3) provides that the increasing value condition is not satisfied if the whole or substantially the whole of the assets of the issuing company are income producing.
S527(4) provides an exhaustive list of assets which are ‘income producing’ for the purposes of S527. These are -
•any share within S524;
•any share itself within the increasing value condition of S524, or would be but for the income producing assets test;