130. Disguised Interest. | Taxation Law | LexisNexis

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130. Disguised interest.

The provisions relating to disguised interest¹ apply where a person is party to an arrangement² which produces for the person a return in relation to any amount which is economically equivalent to interest³.

Income tax is charged on the return if the return is not charged to income tax under or as a result of any other provision of the

(6) Savings And Investment Income

126. Introduction to savings and investment income.

127. Charge to tax.

128. Meaning of 'interest'.

129. Interest awarded in legal proceedings.

130. Disguised interest.

131. Transactions in deposits.

132. Premiums and discounts.

133. Extra return on new issues of securities.

134. Capitalisation of interest.

135. Arrangements for payment of fixed net amount.

136. Charge to tax.

137. In general.

138. Dividends.

139. Distributions out of assets.

140. Redeemable share capital and security.

141. Interest and other distributions out of assets.

142. Transfers between a company and its members.

143. Bonus issues following repayment of share capital.

144. Repayment of share capital.

145. Other amounts treated as distributions: arrangements offering a choice of capital or income return.

146. Interest or other distribution paid in respect of certain securities.

147. Stock dividends treated as income.

148. Returns.

149. Charge to income tax on stock dividend income.

150. Liability to counteraction of tax advantage from transactions in securities.

151. Effect on the borrower and lender of repos and relevant arrangements.

152. Charge to tax.

153. Receipts from intellectual property.

154. Income from certain telecommunication rights.

155. Annual payments not otherwise charged to tax.

156. Meaning of 'annual payments'.

157. Annual payments general exemptions from tax.

158. Income and capital payments distinguished.

159. Annuities paid out of capital.

160. Purchase of annuities.

161. Antecedent debt.

162. Sale of asset.

163. Payment of certain or uncertain annual amounts.

164. Payments under partnership agreements.

165. Purchased life annuities.

166. Computation of the exempt proportion and the exempt amount.

167. Annuities excepted from relief.

168. Immediate needs annuities.

169. Discounts.

170. Deeply discounted securities.

171. Manufactured payments and dividends.

172. Source of income.

173. Income arising and basis of assessment.

174. Collection and deduction at source.

175. Avoidance of agreements for payment without deduction of tax.

176. Provisions in court orders for payment without deduction of tax.

177. Damages and compensation for personal injury.

178. Cases where tax is not deductible at source.

179. Introduction.

180. Meaning of 'yearly interest'.

181. Administrative provisions where tax is deductible at source by a company resident in the United Kingdom.

182. Administrative provisions where tax is deductible at source by a person other than a company.

183. Statement of tax deducted.

184. Time for deduction of tax.

185. Arrangements for payment of interest less tax or of fixed net amounts.

186. Payments under discretionary trusts.

187. Deduction of tax from qualifying annual payments.

188. Annual payments for non-taxable consideration.

189. Patent, copyright and similar royalties.

190. What constitutes payment.

191. 'Such sum as after deduction of tax'; 'free of tax'.

192. Charge to tax.

193. Temporary non-residents.

194. Shares in approved share incentive plans ('SIPs').

195. Effect of Crown option to assess.

196. Meaning of 'relevant foreign income'.

197. Relevant foreign income charged on the remittance basis.

198. Relevant foreign income charged on the arising basis.

199. Relief for backdated pensions charged on the arising basis.

200. Unremittable income.

201. Charge on income arising from relevant transfer.

202. Charge where there is power to enjoy income.

203. Charge where capital sums are received.

204. Charge where benefit is received.

205. Introduction.

206. No duplication of charges.

207. Rates of tax, deductions and reliefs.

208. Amounts corresponding to accrued income profits and related interest.

209. Power to obtain information.

210. Restrictions on particulars to be provided by relevant lawyers.

211. Restrictions on particulars to be provided by banks.

212. Appeals.

213. Charge to tax on accrued income profits.

214. Meaning of 'securities'.

215. Transfers of securities: meaning.

216. Kinds of transfer.

217. Calculating accrued income profits and losses.

218. Payment treated as made on transfer with accrued interest.

219. Payment treated as made on transfer without accrued interest.

220. Exception where there is a transfer to a legatee.

221. Relief for losses.

222. Relief for unremittable transfer proceeds.

223. Individuals to whom remittance basis applies.

224. Excluded persons.

225. Other transactions treated as transfers.

226. Excluded transfers.

227. Transfers by or to nominees or trustees.

228. Trustees' accrued income profits treated as settlement income.

229. Exemptions.

230. Charge to tax and scope of charge.

231. Income charged by regulations.

232. Undertakings analogous to trade.

233. Casual profits of a revenue nature.

234. Annual payments not otherwise charged.

235. Income not otherwise charged.

236. Income from certain foreign holdings.

237. Application of the alternative basis of charge.

238. Limit on tax charged.

239. Delayed remittances.

240. Remittance to United Kingdom.

241. Amount remitted.

242. Remittances from mixed funds.

243. Exempt property.

244. Alternative finance arrangements in general.