Taxes Consolidation Act 1997 section 267N

Interpretation

Section 267N defines the key terms used in the tax rules governing specified financial transactions, which include credit transactions, deposit transactions, and investment transactions.

• A credit transaction arises where a finance undertaking acquires and disposes of an asset in a manner equivalent to a loan at interest, and can take the form of a credit sale, a buy-and-sell-back arrangement, or a joint acquisition (diminishing shared ownership).
• A deposit transaction arises where a person deposits money with a relevant deposit taker and receives payments from profits generated by the use of that money, in proportion to the amount deposited.
• An investment transaction arises where a person acquires investment certificates and receives an investment return equivalent to interest on a conventional bond.
• References to consideration exclude any reclaimable VAT and any fees or charges imposed by the finance undertaking, and are construed as the aggregate of all amounts paid or payable.