Commentary

B5.706 Exceptions to charge to tax

Business tax
Business tax | Commentary

B5.706 Exceptions to charge to tax

Business tax | Commentary

B5.706 Exceptions to charge to tax

No charge to tax arises if any of the following conditions apply:

  1.  

    (a)     the participant is required to treat the interest in the fund as a loan relationship under CTA 2009, ss 487–497 (Pt 6, Ch 3) (see D1.788) or as a derivative contract to which CTA 2009, ss 570–710 (Pt 7) applies (see Division D1.8)1

  2.  

    (b)     the asset is a intangible fixed asset to which CTA 2009, ss 711–906 (Pt 8) applies (see Division D1.6), consists of excluded indexed securities (as defined in ITTOIA 2005, s 433, see D9.503) or is a right arising under an insurance policy2

  3.  

    (c)     the interest in the fund is held as trading stock or the disposal of the interest is taken into account in computing trade profits (see Division B4.1)3

  4.  

    (d)     there is a disposal of assets of an

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