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Section 564S Treatment of bond-holder and bond-issuerF1C1C2

United Kingdom

(1)

This section applies for the purposes of the Income Tax Acts and irrespective of the position for other purposes.

(2)

The bond-holder under investment bond arrangements is not treated as having a legal or beneficial interest in the bond assets.

(3)

The bond-issuer under such arrangements is not treated as a trustee of the bond assets.

(4)

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).

(5)

Payments made by the bond-issuer by way of redemption payment or additional payment are not made in a fiduciary or representative capacity.

(6)

The bond-holder is not entitled to relief for capital expenditure in connection with the bond assets.

(7)

Expressions used in this section have the same meaning as in section 564G.

Annotations

Textual amendments

F1

S. 564S inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 2 para. 20 (with Sch. 9 paras. 1-9, 22)

Modifications

C1

S. 564S applied by 2009 c. 10, Sch. 61 para. 2 (as substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 229(3) (with Sch. 9 paras. 1-9, 22))

C2

S. 564S applied (S.) (1.4.2015) by Land and Buildings Transaction Tax (Scotland) Act 2013 (asp 11), s. 70(2), sch. 8 para. 6 (with s. 69); S.S.I. 2015/108, art. 2

Notes on Part 10A

Textual amendments

F1

Pt. 10A inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 2 para. 2 (with Sch. 9 paras. 1-9, 22)

Notes on Special rules for investment bond arrangements

Textual amendments

F1

S. 564R and cross-heading inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 2 para. 19 (with Sch. 9 paras. 1-9, 22)