‘Quasi-interest’ avoidance schemes (CTA09/S547)

This guidance applies up to 21 April 2009

This anti-avoidance provision is aimed at schemes designed to produce non-taxable interest-like returns using arrangements similar to creditor repos and creditor quasi-repos.

The provision applies if all of the following conditions are met:

Under an arrangement a person (not necessarily a company) receives any money or other asset (‘the advance’) from a company (or a partnership of which the company is a member).

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