CFM45000 - Deemed loan relationships: shares with guaranteed returns (‘shares as debt’)

Contents

CFM45010

Shares with guaranteed returns: introduction

CFM45020

Shares with guaranteed returns: examples of avoidance schemes

CFM45030

Shares with guaranteed returns: outline of legislation

CFM45040

Shares with guaranteed returns: main sections of legislation

CFM45050

Shares with guaranteed returns: outstanding third party obligations

CFM45060

Shares with guaranteed returns: outstanding third party obligations: debits and credits

CFM45070

Shares with guaranteed returns: outstanding third party obligations: meaning of outstanding third party obligations

CFM45080

Shares with guaranteed returns: outstanding third party obligations: meaning of interest-like investment

CFM45090

Shares with guaranteed returns: outstanding third party obligations: comparison with commercial rate of interest

CFM45100

Shares with guaranteed returns: outstanding third party obligations: repos and stock loans

CFM45110

Shares with guaranteed returns: non-qualifying shares

CFM45120

Shares with guaranteed returns: non-qualifying shares: debits and credits

CFM45130

Shares with guaranteed returns: non-qualifying shares: meaning of non-qualifying shares

CFM45140

Shares with guaranteed returns: non-qualifying shares: repos and stock loans

CFM45150

Shares with guaranteed returns: non-qualifying shares: the increasing value condition

CFM45160

Shares with guaranteed returns: non-qualifying shares: definition of income producing assets

CFM45170

Shares with guaranteed returns: non-qualifying shares: the income producing assets test

CFM45180

Shares with guaranteed returns: non-qualifying shares: the income producing assets test: groups

CFM45190

Shares with guaranteed returns: non-qualifying shares: application of the increasing value condition

CFM45200

Shares with guaranteed returns: non-qualifying shares: the redemption return condition

CFM45210

Shares with guaranteed returns: non-qualifying shares: the redemption return condition: meaning of excepted shares

CFM45220

Shares with guaranteed returns: non-qualifying shares: the redemption return condition: meaning of qualifying publicly issued shares

CFM45230

Shares with guaranteed returns: non-qualifying shares: the redemption return condition: mirroring a public issue of shares

CFM45240

Shares with guaranteed returns: non-qualifying shares: the redemption return condition: unallowable purposes test

CFM45250

Shares with guaranteed returns: non-qualifying shares: the associated transactions condition

CFM45260

Shares with guaranteed returns: non-qualifying shares: the associated transactions condition: meaning of associated transaction

CFM45270

Shares with guaranteed returns: beginning or ceasing to be within the rules

CFM45280

Shares with guaranteed returns: shares changing ownership in a group

CFM45290

Shares with guaranteed returns: 16 March 2005 transitional rules

CFM45300

Shares with guaranteed returns: schemes unwound by 31 December 2005

CFM45310

Shares with guaranteed returns: meaning of commercial rate of interest

CFM45320

Shares with guaranteed returns: meaning of commercial rate of interest: simple commercial rate

CFM45330

Shares with guaranteed returns: interaction with arbitrage rules and capital gains