26After section 564X insert—
(1)This section applies if arrangements to which section 564H (provision not at arm’s length: exclusion of arrangements from sections 564C to 564G) applies would, but for that section, be alternative finance arrangements.
(2)A person paying relevant return under the arrangements is not entitled to—
(a)any deduction in respect of the relevant return in calculating profits or other income for income tax purposes, or
(b)any deduction in respect of the relevant return in calculating net income.
(3)In this section “relevant return” has the same meaning as in section 564H (see subsection (3) of that section).”