Section 564J — Income Tax Act 2007: Purchase and resale arrangements where return in foreign currency

Purchase and resale arrangements where return in foreign currency 564J 1 If, in the case of purchase and resale arrangements, alternative finance return is paid in a currency other than sterling—

a by or to a person other than a company, and b otherwise than for the purposes of a trade, profession or vocation or a property business, subsections (2) and (3) apply as respects that person.

2 The amount of the excess referred to in section 564I(2) and (5)(b) and the appropriate amount for the purposes of section 564I(3) and (4) are to be calculated in that other currency.

3 The amount of each payment of alternative finance return is to be translated into sterling at a spot rate of exchange for the day on which the payment is made.