{
  "url": "https://openlegislation.uk/income-tax-act-2007/section-164",
  "json_url": "https://openlegislation.uk/income-tax-act-2007/section-164.json",
  "legislation": "ukpga/2007/3",
  "legislation_title": "Income Tax Act 2007",
  "legislation_url": "https://openlegislation.uk/income-tax-act-2007",
  "path": "section/164",
  "kind": "section",
  "number": "164",
  "heading": "The no linked loans requirement",
  "text": "(1) No linked loan is to be made by any person, at any time in period A, to the investor or an associate of the investor.\n(2) In this section “linked loan” means any loan which—\n(a) would not have been made, or\n(b) would not have been made on the same terms,\nif the investor had not subscribed for the relevant shares, or had not been proposing to do so.\n(3) References in this section to the making by any person of a loan to the investor or an associate of the investor include references—\n(a) to the giving by that person of any credit to the investor or any associate of the investor, and\n(b) to the assignment to that person of a debt due from the investor or any associate of the investor.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2007/3/section/164",
    "retrieved_at": "2026-10-29T09:13:03.599581+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."
}