Section 520 Provision not at arm's length: non-deductibility of relevant return

United Kingdom

(1)

This section applies if arrangements to which section 508 (provision not at arm's length: exclusion of arrangements from sections 503 to 507) applies would, but for that section, be alternative finance arrangements.

(2)

A company paying relevant return under the arrangements is not entitled to—

(a)

any deduction in calculating profits or gains for corporation tax purposes, or

(b)

any deduction F1from total profits,

in respect of the relevant return.

(3)

In this section “relevant return” has the same meaning as in section 508 (see subsection (3) of that section).

Annotations

Textual amendments

F1: Word in s. 520(2)(b) 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. 633 (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)