Section 412 — Corporation Tax Act 2009: Persons indirectly standing in the position of creditor

Persons indirectly standing in the position of creditor 412 1 For the purposes of sections 407(1)(b) and 409 a person is treated as standing in the position of a creditor if the person indirectly stands in that position by reference to a series of loan relationships or relevant money debts.

2 If a company (“C”) is so treated for the purposes of section 407(1)(b), the reference in section 407(1)(e) to the corresponding creditor relationship is a reference to C's creditor relationship.

3 If a person (“P”) is so treated for the purposes of section 409, the reference in section 410(2)(b) to the corresponding creditor relationship is a reference to P's creditor relationship.

4 In subsection (1) “ relevant money debt ” means a money debt which would be a loan relationship if a company directly stood in the position of creditor or debtor.