CFM40110 - Loan relationships: deemed loan relationships: overview
Relationships treated as loan relationships: overview
CTA09/S302 defines a loan relationship as a money debt, that arises from a transaction for the lending of money.
Certain types of financial arrangements, and the rights and payments made under those arrangements, do not fall within this definition, but are nevertheless brought within the loan relationship rules by CTA09/PT6.
Part 6 refers to these as 바카라 사이트˜relationships treated as loan relationships바카라 사이트™. For convenience, in the Corporate Finance Manual we refer to these as 바카라 사이트˜deemed loan relationships바카라 사이트™. Broadly, these 바카라 사이트˜deemed loan relationships바카라 사이트™ fall into three categories.
- 바카라 사이트˜Money debts바카라 사이트™ that do not 바카라 사이트˜arise from the lending of money바카라 사이트™ (Chapter 2 of Part 6 CFM40120.)
- Investments in certain types of investment fund and mutual arrangement (Chapters 3 to 5 of Part 6 CFM40130.)
- Arrangements that give an interest-like return (Chapters 2A and 6 to 11 CFM40140.)
In each case the legislation provides for the rules in CTA09/PT5 to apply to these 바카라 사이트˜deemed loan relationships바카라 사이트™ as if they are loan relationships, and CTA09/S294(2) provides generally that references to 바카라 사이트˜Part 5바카라 사이트™ in the Tax Acts includes references to 바카라 사이트˜Part 6바카라 사이트™.