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The measures discussed in this article and D1.794 are designed to counter two broad types of avoidance arrangements:

1. Ìý

   •ÌýÌýÌýÌý Where an asset, or right to income, is transferred by a taxpayer (the borrower) to another person (the lender) for a period of time and in accordance with generally accepted accounting practice the transaction is shown as a financing transaction in the borrower's accounts. These measures also apply where an asset was not income producing at the time of the transfer and after the transfer income arising on the asset is received by a person other than the borrower¹. This is termed a Type 1 finance arrangement in the legislation and

2. Ìý

   •ÌýÌýÌýÌý Where the right to some or all of the income on an asset is transferred to another person via the use of a partnership and in accordance with generally accepted accounting practice the transaction is shown as a financing transaction in the accounts of the partnership, or of a member of the partnership². This measure also applies where the income