CFM45450 - Deemed loan relationships: returns from partnerships: definitions for CTA09/S536, S537 and S538

Overview of legislation: definitions

This guidance applies to companies that have interests in partnerships up to 21 April 2009

The following words or phrases appear in the legislation at CTA09/PT6/CH8 and are defined as follows:

Relevant arrangements

鈥楻elevant arrangements鈥� means:

  • Arrangements which are designed to produce a return for the company equivalent, in substance, to a return on the investment of money at a commercial rate of interest, and
  • The purpose or one of the main purposes of the arrangements is to secure a tax advantage.

Connected persons

鈥楥onnected persons鈥� takes its meaning from CTA10/S1122.

Arrangements

鈥楢rrangements鈥� includes any agreement, understanding, scheme, transaction or series of transactions.

Tax advantage

鈥楾ax advantage鈥� has the meaning given to it be CTA10/S1139.

Due Share

鈥楧ue share鈥� of profit or capital is the share of profit or capital that the company would have been allocated or entitled to had it been allocated or entitled to a share by reference to the proportion of total capital contributed by it.