Corporation Tax Act 2010 section 357LB

Alternative finance arrangements

Section 357LB ensures that a company receiving alternative finance returns is not treated as having a Northern Ireland Regional Establishment (NIRE) solely because of activities carried out in connection with those alternative finance arrangements.

• Where a company receives an alternative finance return, the activities of the other party to the arrangements, or of any person acting for the company in relation to them, do not by themselves create a NIRE.
• Alternative finance return means a return falling within specified sections of ITA 2007 (sections 564I, 564K, or 564L(2) or (3)) or CTA 2009 (sections 511, 512, or 513(2) or (3)).
• The protection applies specifically to the alternative finance arrangements under which the relevant alternative finance return is paid.
• This prevents Sharia-compliant and other alternative finance structures from inadvertently creating a taxable Northern Ireland presence for the company.