# Taxation (International and Other Provisions) Act 2010, Paragraph 20


After section 564R insert—
“Treatment of bond-holder and bond-issuer
564S (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.”

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Source: https://www.legislation.gov.uk/ukpga/2010/8/schedule/2/paragraph/20 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-2/paragraph-20
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.