CFM6390 - Taxing Loan Relationships: anti-avoidance: partnerships

When S91H-I have effect

Finance Act 2008 introduced anti-avoidance provisions targeting schemes which used partnerships to convert what is economically interest into either capital gains or tax nothings.

The rules apply to returns arising to a company from interests in partnerships on or after 12March 2008 (i.e. Budget Day).

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