Section 486G Consideration to be treated as loan relationshipF1
United Kingdom
For the purposes of this Part—
the consideration for the transfer of the right to relevant receipts is to be treated as a money debt which is owed to the transferee by the person by whom the relevant receipts fall to be paid, and
the transfer is to be treated as a transaction for the lending of money from which that debt is treated as arising.
For the meaning of “relevant receipts” see F2section 752(2) of CTA 2010 or section 809AZA(2) of ITA 2007.
Annotations
Textual amendments
- F1
Pt. 6 Ch. 2B inserted (with effect in accordance with Sch. 25 para. 10 of the amending Act) by Finance Act 2009 (c. 10), Sch. 25 para. 8(3)
- F2
Words in s. 486G(2) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 626 (with Sch. 2)
Notes on Part 6
Modifications
- C1
Pt. 6 modified (for the tax year 2026-27 and subsequent tax years (but in relation to investment management services whenever performed)) by 2005 c. 5, Sch. A1 para. 35(7) (as inserted by Finance Act 2026 (c. 11), s. 58(6), Sch. 11 para. 1)