Section 517 Treatment of bond-holder under investment bond arrangements
This section applies for the purposes of the Corporation Tax Acts and irrespective of the position for other purposes.
The bond-holder under investment bond arrangements is not treated as having a legal or beneficial interest in the bond assets.
The bond-issuer under such arrangements is not treated as a trustee of the bond assets.
Profits accruing to the bond-issuer in connection with the bond assets are profits of the bond-issuer and not of the bond-holder (and do not arise to the bond-issuer in a fiduciary or representative capacity).
Payments made by the bond-issuer by way of redemption payment or additional payment are not made in a fiduciary or representative capacity.
The bond-holder is not entitled to relief for capital expenditure in connection with the bond assets.
Expressions used in this section have the same meaning as in section 507.
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)