3(1)In paragraph 1 of Schedule 9 to FA 1996 (loan relationships: distributions), after sub-paragraph (1) insert—U.K.
“(1A)Credits relating to any amount which falls, when paid, to be treated as a distribution in respect of a loan relationship are to be brought into account for the purposes of this Chapter if the amount arises in consequence of, or otherwise in connection with, arrangements the purpose, or one of the main purposes, of which is securing for any person a tax advantage; and for this purpose—
(a)“arrangements” includes any agreement, understanding, scheme, transaction or series of transactions, and
(b)“tax advantage” has the meaning given by section 840ZA of the Taxes Act 1988.”
(2)The amendment made by sub-paragraph (1) has effect in relation to accounting periods ending on or after 12 March 2008 but, in the case of an accounting period beginning before that date, only if the credits relate to any time on or after that date.