A7.219 Off-market terms

A7.219 Off-market terms

This hallmark was omitted with effect from 1 January 20111 and prescribed arrangements where:

  1.  

    •     the tax advantage arose, to more than an incidental degree, from the inclusion of a financial product

  2.  

    •     a promoter or someone connected with him became a party to the financial product, and

  3.  

    •     the price of the financial product differed significantly from what might reasonably have been expected in the open market

A financial product for these purposes was:

  1.  

    •     a loan

  2.  

    •     a contract which was (or would have been under certain circumstances) a derivative contact under FA 2002, Sch 26

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