(1) an amount ('manufactured interest') is payable by or on behalf of, or to, any company under any arrangement relating to the transfer of an asset representing a loan relationship1; and
(2) that amount is, or (when paid) will fall to be treated as, representative of interest under that relationship ('the real interest')2, the company has a manufactured interest relationship for the purposes of Corporation Tax Acts3.
For these purposes4, any manufactured interest under the manufactured interest relationship payable:
(a) by the company must be treated as it would be if the manufactured interest were interest payable on a
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