The tax treatment of the various alternative finance arrangements are as detailed below.
Purchase and re-sale arrangement/Diminishing shared ownership arrangement
Where a company is a party to a purchase and resale arrangement or a diminishing shared ownership arrangement within the provisions described in B5.602A, the loan relationships regime has effect in relation to the arrangements as if the:
- Ìý
•ÌýÌýÌýÌý arrangements were a loan relationship to which the company is a party
- Ìý
•ÌýÌýÌýÌý amount of the purchase price of the asset were the amount of a loan made to the company by, or by the company to, the other party to the arrangements, and
- Ìý
•ÌýÌýÌýÌý alternative finance return payable to or by the company under the arrangements were interest payable under that loan relationship1
For a corporate vendor, it is instructive to contrast a sale by a financial institution (or post May 2022 the arrangements being regulated electronic system facilitated arrangements) falling within the purchase and resale rules described in B5.602A with a sale on
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:42