{
  "url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-554F",
  "json_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-554F.json",
  "legislation": "ukpga/2003/1",
  "legislation_title": "Income Tax (Earnings and Pensions) Act 2003",
  "legislation_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003",
  "path": "section/554F",
  "kind": "section",
  "number": "554F",
  "heading": "Exclusions: commercial transactions",
  "text": "(1) Chapter 2 does not apply by reason of a relevant step which is the payment of a sum of money by way of a loan if—\n(a) the loan is a loan on ordinary commercial terms within the meaning of section 176, ignoring conditions B and C in that section, and\n(b) there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.\n(2) Chapter 2 does not apply by reason of a relevant step taken by a person (“P”), which is not the payment of a sum of money by way of a loan, if—\n(a) the step is taken for the sole purpose of a transaction which P has with A and which P entered into in the ordinary course of P's business,\n(b) a substantial proportion of P's business involves similar transactions with members of the public,\n(c) the terms on which P entered into the transaction with A are substantially the same as the terms on which P normally enters into similar transactions with members of the public, and\n(d) there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.\n(3) For the purposes of subsection (2)(b) and (c) a transaction is “similar” if it is of the same or a similar type to the transaction which P has with A.\n(4) In subsection (2)(b) and (c) “members of the public” means members of the public at large with whom P deals at arm's length.\n(5) In this section references to A include references to any person linked with A.\n(6) See paragraph 25 of Schedule 11 to F(No. 2)A 2017 for provision about exclusions where a loan is made on ordinary commercial terms and the relevant step is within paragraph 1 of that Schedule.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 7A inserted (with effect in accordance with Sch. 2 paras. 52-59 of the amending Act) by Finance Act 2011 (c. 11), Sch. 2 para. 1"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 554F(6) inserted (16.11.2017) by Finance (No. 2) Act 2017 (c. 32), Sch. 11 para. 26"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2003/1/section/554F",
    "retrieved_at": "2026-10-29T09:18:42.395488+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."
}