BIM45780 - Specific deductions: interest: alternative finance arrangements: overview and commencement date
FA05 introduced legislation on alternative finance arrangements.
FA05 identified two types of alternative finance arrangement that
are in substance used for the lending of money, although in form
the transactions involve the purchase and sale of an asset or a
profit sharing contract.
These two types of arrangement are described in FA05 as
giving rise to either:
- an alternative finance return (called an alternative finance return arrangement, see CFM6051),
- or a profit share return (called a profit share return arrangement, see CFM6054).
A full description of alternative finance arrangements and the
calculation of the alternative finance return or profit share
return is given in CFM6050 onwards.
An alternative finance return arrangement can be used as an
alternative to a conventional loan or provide a return to a
customer depositing money in a bank. A profit share return
arrangement is an alternative to a conventional interest return on
a bank deposit. The FA05 legislation says that where there a
transaction is an alternative finance arrangement the return from
that arrangement (either the alternative finance return or profit
share return) is treated for UK tax purposes as if it were
interest.
The legislation applies to payments of alternative finance
return and profit share return made on or after the 6 April 2005
from:
- alternative finance return arrangements entered into on or after the 6 April 2005, and
- profit share return arrangements whenever entered into as long as payments of profit share return are made on or after the 6 April 2005.
