{
  "url": "https://openlegislation.uk/finance-act-2017/schedule-6/paragraph-8",
  "json_url": "https://openlegislation.uk/finance-act-2017/schedule-6/paragraph-8.json",
  "legislation": "ukpga/2017/10",
  "legislation_title": "Finance Act 2017",
  "legislation_url": "https://openlegislation.uk/finance-act-2017",
  "path": "schedule/6/paragraph/8",
  "kind": "paragraph",
  "number": "8",
  "heading": null,
  "text": "After section 554R insert—\n“Exclusions: relevant repayments\n554RA (1) This section applies (subject to subsection (5)) if—\n(a) a right to repayment of principal under a relevant loan (the “repayment right”) is held by or on behalf of a person (“P”), and\n(b) on or after 9 December 2010, a sum of money (the “repayment sum”) is acquired by or on behalf of P by way of repayment of principal under the relevant loan.\n(2) In this section “relevant loan” means a loan made on or after 6 April 1999.\n(3) Subsection (4) applies if—\n(a) on its acquisition, the repayment sum is the subject of a relevant step within section 554B taken by P, or\n(b) for the sole purpose of the acquisition, the making of the payment of the repayment sum is a relevant step within section 554C(1)(a).\n(4) Chapter 2 does not apply by reason of the relevant step if, on its acquisition, the repayment sum is held by or on behalf of P on the same basis as that on which the repayment right was held by or on behalf of P immediately before the acquisition.\n(5) This section does not apply where there is any connection (direct or indirect) between the acquisition by or on behalf of P of the repayment sum and a tax avoidance arrangement (other than the arrangement under which the relevant loan was made).”",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2017/10/schedule/6/paragraph/8",
    "retrieved_at": "2026-10-29T09:05:39.776683+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}