Section 517 — Corporation Tax Act 2009: Treatment of bond-holder under investment bond arrangements

Treatment of bond-holder under investment bond arrangements 517 1 This section applies for the purposes of the Corporation Tax Acts and irrespective of the position for other purposes.

2 The bond-holder under investment bond arrangements is not treated as having a legal or beneficial interest in the bond assets.

3 The bond-issuer under such arrangements is not treated as a trustee of the bond assets.

4 Profits accruing to the bond-issuer in connection with the bond assets are profits of the bond-issuer and not of the bond-holder (and do not arise to the bond-issuer in a fiduciary or representative capacity).

5 Payments made by the bond-issuer by way of redemption payment or additional payment are not made in a fiduciary or representative capacity.

6 The bond-holder is not entitled to relief for capital expenditure in connection with the bond assets.

7 Expressions used in this section have the same meaning as in section 507.