{
  "url": "https://openlegislation.uk/income-tax-act-2007/section-564S",
  "json_url": "https://openlegislation.uk/income-tax-act-2007/section-564S.json",
  "legislation": "ukpga/2007/3",
  "legislation_title": "Income Tax Act 2007",
  "legislation_url": "https://openlegislation.uk/income-tax-act-2007",
  "path": "section/564S",
  "kind": "section",
  "number": "564S",
  "heading": "Treatment of bond-holder and bond-issuer",
  "text": "(1) This section applies for the purposes of the Income Tax Acts and irrespective of the position for other purposes.\n(2) The bond-holder under investment bond arrangements is not treated as having a legal or beneficial interest in the bond assets.\n(3) The bond-issuer under such arrangements is not treated as a trustee of the bond assets.\n(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).\n(5) Payments made by the bond-issuer by way of redemption payment or additional payment are not made in a fiduciary or representative capacity.\n(6) The bond-holder is not entitled to relief for capital expenditure in connection with the bond assets.\n(7) Expressions used in this section have the same meaning as in section 564G.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "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)"
    },
    {
      "type": "C",
      "label": "C1",
      "text": "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))"
    },
    {
      "type": "C",
      "label": "C2",
      "text": "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"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2007/3/section/564S",
    "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."
}