Part XIX, Section 824 · Income and Corporation Taxes Act 1988

Contents

824Repayment supplements: individuals and others.#

(1)Subject to the following provisions of this section, a repayment made by the Board or an officer of the Board of any of the following, namely—

(a)an amount paid on account of income tax under section 59A of the Management Act;

(b)any income tax paid by or on behalf of an individual for a year of assessment;

(c)

(i)

(ii)

(d)a penalty incurred by an individual under any of the provisions of that Actthe Finance Act 2009 or Schedules 24 to 26 to the Finance Act 2021,

shall be increased under this section by an amount (a “repayment supplement”) equal to interest on the amount repaid at the rate applicable under section 178 of the Finance Act 1989 for the period (if any) between the relevant time and the date on which the order for the repayment is issued.

(1A). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(2)^note. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(2A)Subsection (1) above shall apply to a repayment made in consequence of a claim under section 228 of the Income Tax Act 1952 (relief in respect of income accumulated under trusts) as if the repayment were of income tax paid by the claimant for the year of assessment in which the contingency mentioned in that section happened.

(2B)Subsection (1) above shall apply to a payment made by the Board under section 375(8) (payment of amount which borrower would have been able to deduct from interest payment under section 369(1)) as if the payment were a repayment falling within that subsection.

(2C)Subsection (1) above shall apply to a repayment made by the Board as a result of a claim for relief under—

(a)paragraph 2 of Schedule 1B to the Management Act (carry back of loss relief),

(b)paragraph 3 of that Schedule (relief for fluctuating profits of farming etc.), or

(c)Schedule 4A to this Act (relief for fluctuating profits of creative artists etc.),

as if it were a repayment falling within that subsection.

(2D)Subsection (1) shall apply—

(a). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(b)to a payment made under paragraph 6(1) of Schedule 14 (payment where entitlement to life assurance premium relief has not been given by deduction) as if the payment were a repayment of income tax paid for the tax year in which the entitlement to relief arose.

(3)For the purposes of subsection (1) above—

(a)if the repayment is—

(i)the repayment of an amount paid in accordance with the requirements of section 59A of the Management Act on account of income tax for a year of assessment, or

(ii)the repayment of income tax for such a year which is not income tax deducted at source (other than a repayment within paragraph (ac)),

the relevant time is the date of the payment that is being repaid;

(aa)if the repayment is a payment made by the Board under section 375(8), the relevant time is—

(i)if the interest payment was made in the year 1996-97 or a subsequent year of assessment, the 31st January next following that year;

(ii)if the interest payment was made in an earlier year of assessment, the 5th April next following that year;

(ab)if the repayment is a repayment as a result of a claim for relief under any of the provisions mentioned in subsection (2C) above, the relevant time is the 31st January next following the year that is the later year in relation to the claim;

(ac)if the repayment is a repayment as a result of a claim under section 496B of ITA 2007 (relief for payments by discretionary trust taxable as employment income), the relevant time is the 31 January next following the end of the tax year to which the claim relates;

(ad)if the repayment is a payment falling within subsection (2D)(b), the relevant time is 31 January next following the end of the tax year in which the entitlement to relief arose;

(b)if the repayment is of income tax deducted at source for a year of assessment, the relevant time is the 31st January next following that year; and

(c)if the repayment is of a penalty or surcharge, the relevant time is the date on which the penalty or surcharge was paid.

(4)For the purposes of subsection (3) above, where a repayment in respect of income tax for a year of assessment is made to any person, that repayment—

(a)shall be attributed first to so much of any payment made by him under section 59B of the Management Act as is a payment in respect of income tax for that year;

(b)in so far as it exceeds the amount (if any) to which it is attributable under paragraph (a) above, shall be attributed in two equal parts to each of the payments made by him under section 59A of the Management Act on account of income tax for that year;

(c)in so far as it exceeds the amounts (if any) to which it is attributable under paragraphs (a) and (b) above, shall be attributed to income tax deducted at source for that year; and

(d)in so far as it is attributable to a payment made in instalments shall be attributed to a later instalment before being attributed to an earlier one.

(4A)In this section any reference to income tax deducted at source for a year of assessment is a reference to—

(a)income tax deducted or treated as deducted from any income, or treated as paid on any income, in respect of that year, ^note. . .

(b). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

but does not include a reference to amounts which, in that year, are deducted at source under PAYE regulations in respect of previous years.

(5). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(6)^note... The Treasury may by order from time to time increase or decrease the rate of interest by reference to which—

(a)repayment supplements are calculated under subsection (1) above; and

(b)repayment supplements are calculated under section 47 of the Finance (No. 2) Act 1975.

(7)A repayment supplement shall not be payable under this section in respect of a repayment or payment made in consequence of an order or judgment of a court having power to allow interest on the repayment or payment, or in respect of a repayment of a post-war credit within the meaning of the Income Tax (Repayment of Post-War Credits) Act 1959.

(8). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(9)^noteSubsections (1) to (7) above shall apply in relation to ^note. . . the trustees of a settlement, scheme administrators of registered pension schemes sub-scheme administrators of sub-schemes which form part of a split scheme pursuant to the Registered Pensions (Splitting of Schemes) Regulations 2006or personal representatives ^note ... as they apply in relation to an individual.

(10). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Contains public sector information licensed under the Open Government Licence v3.0.

Defined terms · 200

Show every defined term

a group of companies
means a company and any other companies of which it has control.
a holding company
means a company that has one or more 51% subsidiaries from which it receives or has received one or more distributions.
a production herd
means, in relation to a farmer, a herd of animals of the same species (irrespective of breed) kept by the farmer wholly or mainly for the sake of the products which they produce for the farmer to sell, being products obtainable from the living animal.
a qualifying overseas transfer
means so much of any transfer of the whole or any part of the business of an overseas life insurance company carried on through a branch or agency in the United Kingdom as takes place in accordance with any authorisation granted outside the United Kingdom for the purposes of Article 11 of the third life insurance Directive.
alternative finance return
has the meaning given in sections 564I to 564L of ITA 2007, and • “purchase and resale arrangements” means arrangements to which section 564C of ITA 2007 applies.
amend
includes revoke and “amendment” has a corresponding meaning.
an equivalent manual car
means a car that—
appropriate amount in cash
has the meaning given by section 251(2).
appropriate policy holder
means— (a) in relation to an assignment of part of or a share in the rights conferred by a policy or contract, any person who is both— (i) the policy holder, or one of the policy holders, immediately before the assignment;
approved
means— (a) in relation to an SAYE option scheme, approved under Schedule 3 to that Act (approved SAYE option schemes), and (b) in relation to a CSOP scheme, approved under Schedule 4 to that Act (approved CSOP schemes).
approved stock lending arrangement
means an arrangement such as is mentioned in subsection (1), (2) or (2A) of section 129 and in relation to which that section and section 271(9) of the 1992 Act apply;
arrangement
means an arrangement of any kind, whether in writing or not;
arrangements
includes schemes, arrangements and understandings of any kind, whether or not legally enforceable, and shall be taken to include any related transactions;
asset
includes part of an asset.
associate
has the meaning given in subsections (3) and (4) of section 417, except that in those subsections, as applied for the purposes of this paragraph, “relative” shall not include a brother or sister;
avoidance scheme
means a scheme the main purpose, or one of the main purposes, of any party to which in entering into the scheme is to secure that section 748(1)(f) prevents an apportionment falling to be made under section 747(3) as regards an accounting period, or accounting periods, of X;
balance sheet total
has the meaning given by sections 382(5) and 465(5) of the Companies Act 2006;
bank
has the meaning given by section 840A.
basic profits
means the amount of a company’s profits for an accounting period on which corporation tax finally falls to be borne;
basic rate commutable pension
means a pension of one-sixtieth of his relevant annual remuneration for each year of service up to a maximum of 40;
basic rate lump sum
means a lump sum of three-eightieths of his relevant annual remuneration for each year of service up to a maximum of 40;
basic rate non-commutable pension
means a pension of one-eightieth of his relevant annual remuneration for each year of service up to a maximum of 40,
body of persons
includes a partnership, and “control” has the meaning given by section 840.
bonus distribution
means a distribution which in relation to the company making it is a distribution by virtue only of paragraph (c)of section 209(2).
broker
includes any person offering to sell securities to, or purchase securities from, members of the public generally;
business
includes a trade or profession and, for the purposes of sub-paragraph (1)(c) above, any activity of a professional association, joint venture or temporary grouping.
Business travel
means travelling the expenses of which, if incurred and defrayed by the employee in question out of the emoluments of his employment, would (in the absence of sections 197AD to 197AF) be deductible under section 198(1) (general relief for necessary expenses).
capital interest
means an interest in the issued share capital or reserves of the company or in a loan to or deposit with the company or the liability of a guarantor under a guarantee given to or for the benefit of the company;
capital market arrangement
has the same meaning as in section 72B(1) of the Insolvency Act 1986 (see paragraph 1 of Schedule 2A to that Act);
capital market investment
has the same meaning as in section 72B(1) of the Insolvency Act 1986 (see paragraphs 2 and 3 of Schedule 2A to that Act);
capital redemption policy
means a capital redemption policy in relation to which...
Car
means a mechanically propelled road vehicle which is not—
certificate of deposit
means a document relating to money, in any currency, which has been deposited with the issuer or some other person, being a document which recognises an obligation to pay a stated amount to bearer or to order, with or without interest, and being a document by the delivery of which, with or without endorsement, the right to receive that stated amount, with or without interest, is transferable;
chargeable earnings
means general earnings to which any of the charging provisions of Chapter 4 or 5 of Part 2 of ITEPA 2003 apply, and • the “required employment” means the employment by reference to which the individual is eligible to participate in the award.
chargeable event
has the same meaning as in section 552 (see subsection (10) of that section).
child
includes a step-child and an illegitimate child whose parents have married each other after his birth, and “grandchild”, “parent” and “grandparent” have corresponding meanings.
closure notice
means a notice under— (a) section 28A or 28B of the Management Act, or (b) paragraph 32 of Schedule 18 to the Finance Act 1998;
company tax return
means the return required to be delivered pursuant to a notice under paragraph 3 of Schedule 18 to the Finance Act 1998, as read with paragraph 4 of that Schedule;
connected company
means—
contract for a life annuity
means a contract for a life annuity in relation to which...
contract of insurance
has the meaning given by Article 3(1) of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001;
contract of long-term insurance
means a contract which falls within Part II of Schedule 1 to the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001.
contracts of general insurance
means contracts which fall within Part I of Schedule 1 to the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 and “contracts of long-term insurance” means contracts which fall within Part II of that Schedule;
contracts of long-term insurance
means contracts which fall within Part II of Schedule 1 to the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001;
contribution
includes a part of a contribution, and “deductible contribution” means a contribution allowed to be deducted under section 568, any reduction under Part III of Schedule 21 being left out of account.
control
has the meaning given by section 840.
controlled foreign company
has the same meaning as in Chapter 4 of Part 17;
controlling UK person
means a person resident in the United Kingdom who alone, or together with other such persons, controls X.
converting scheme
means a scheme in respect of which an application under paragraph 3(1) above has been made and not withdrawn or finally refused;
cooperative society
has the same meaning as in section 2 of the Co-operative and Community Benefit Societies Act 2014 or, as the case may be, section 1 of the Industrial and Provident Societies Act (Northern Ireland) 1969.
Cycle
has the meaning given by section 192(1) of that Act.
damage
includes any loss, liability, expense or other burden, and references to the amount of any damage are references to the sum which would be fair compensation for that damage;
dealing
includes dealing by way of futures contracts and traded options.
debenture
has the meaning given by section 744 of the Companies Act 1985;
deductible contribution
means a contribution allowed to be deducted under section 568, any reduction under Part III of Schedule 21 being left out of account.
design weight
means the weight which a vehicle is designed or adapted not to exceed when in normal use and travelling on a road laden;
designated
means designated by an order made by the Board for the purposes of that sub-paragraph;
diesel
means any diesel fuel within the definition in Article 2 of Directive 98/70/EC of the European Parliament and of the Council.
discovery assessment
means a discovery assessment under paragraph 41 of Schedule 18 to the Finance Act 1998 (including one by virtue of paragraph 52 of that Schedule);
discovery determination
means a discovery determination under paragraph 41 of that Schedule.
disposal
has the same meaning as in Chapter 8 of Part 4 of ITTOIA 2005.
distributing company
has the meaning given by paragraph 6(1);
distribution
has the same meaning as in the Corporation Tax Acts (see Part 23 of CTA 2010);
distribution period
has the meaning given by paragraph 6(1);
dividend
means a dividend not paid out of specified profits.
dividend manufacturer
has the meaning given by paragraph 2(1) below;
dividend manufacturing regulations
means regulations made by the Treasury under this Schedule;
dividends
means any interest, public annuities, dividends or shares of annuities.
dormant
has the same meaning as in section 1169 of the Companies Act 2006.
double taxation arrangements
means arrangements having effect by virtue of section 788;
dual resident investing company
has the same meaning as in section 404.
earnings charged on remittance
means earnings which are taxable earnings under—
eligible loan
means— and in determining for the purposes of this definition whether the whole or any part of the interest on a loan is so eligible for relief, it shall be assumed that interest at a uniform rate is paid on the loan, whether or not that is in fact the case;
eligible shares
has the same meaning as in section 842AA.
employee
includes an office-holder.
employee benefit trust
has the same meaning as in paragraph 7 of Schedule 8.
employer
includes a prospective employer;
Employment
includes an office and “employee” includes an office-holder.
employment-related loan
means a loan the benefit of which is obtained by reason of a person’s employment (and “non-employment-related loan” shall be construed accordingly).
error
includes—
estate income
means income which is chargeable to tax under Schedule A or Schedule B, and income (other than yearly or other interest)which is chargeable to tax under Schedule D, and which arises from the ownership or occupation of land (including any interest in or right over land)or from the letting furnished of any building or part of a building, but does not include trading income.
estate or trading income
means estate income and trading income.
euro
means the single currency adopted or proposed to be adopted as its currency by a member State in accordance with the Treaty establishing the European Community;
excess liability
means liability to income tax over what it would be if all income tax not chargeable at the lower rateby virtue of section 1(2)(aa) were charged at the basic rate, or (so far as applicable in accordance with section 207A) the lower rate,, to the exclusion of any higher rate;
excess NCDs
has the meaning given by paragraph 6(2);
excess shares
means any share which caused the relevant amount to be exceeded and any share appropriated after that amount was exceeded;
film
means an original master negative of a film, an original master film disc or an original master film tape;
Finance income
means—
financial asset
means a financial asset as defined for the purposes of UK generally accepted accounting practice or international accounting standards;
financial business
means any of the following—
financing arrangements
means arrangements made for providing or guaranteeing, or otherwise in connection with, any debt, capital or other form of finance.
fixed-rate preference shares
means shares which—
foreign dividends
has the meaning given by section 123.
foreign tax
means any tax under the law of a territory outside the United Kingdom or any amount which falls for the purposes of any double taxation arrangements to be treated as if it were such tax;
free shares
has the same meaning as in Schedule 8 to the Finance Act 2000;
friendly society
means the same as in the Friendly Societies Act 1992 (and includes any society that by virtue of section 96(2) of that Act is to be treated as a registered friendly society within the meaning of that Act).
future
means outstanding rights and obligations under a commodity or financial futures contract;
goods vehicle
means a vehicle of a construction primarily suited for the conveyance of goods or burden of any description.
group
means a company and any other companies it controls;
herd
includes a flock, and any other collection of animals however named.
holding company
means—
home loan
means— and in determining for the purposes of this definition whether the whole or any part of the interest on a loan is or would have been so eligible for relief, it shall be assumed that interest at a uniform rate is paid on the loan, whether or not that is in fact the case;
incidental acquisition costs
means any fees, commission, stamp duty and similar incidental costs attributable to the acquisition of the shares.
independent person
means a person— (a) who is not the disadvantaged person, and (b) who does not have a participatory relationship with either of the affected persons.
industrial assurance business
means any industrial assurance business within the meaning given by— which was carried on before 1 December 2001.
inspector
includes any officer of the Board;
insurance group
has the meaning given by paragraph 11A(4);
insurance year
has the same meaning as in Chapter 9 of Part 4 of ITTOIA 2005 (see section 499 of that Act);
intangible asset
means any asset which falls to be treated as an intangible asset in accordance with generally accepted accounting practice.
intellectual property
means—
interest in land
means (subject to sub-paragraph (6) below)— (a) any estate, interest or right in or over land, including any right affecting the use or disposition of land;
interim claim
means an interim claim within the meaning of the relevant regulations;
investment business
means activities within paragraphs (a) to (d) of paragraph 9(1).
investments
(or “investment”) includes futures contracts and options contracts, and
land
includes buildings and other structures, land covered with water, and any estate, interest, easement, servitude, right or licence in or over land.
large risks
means—
loan
means any such loan as is mentioned in section 160(1), and for this purpose sub-paragraphs (4) and (5) below shall be disregarded.
local reinsurance contract
means a reinsurance contract—
long-term insurance fund
has the meaning given by section 431(2).”
losses
includes amounts which are not losses but in respect of which relief may be given in accordance with any of the following enactments— (a) section 1223 of CTA 2009 (excess of management expenses);
mainly trading subsidiary
means a qualifying subsidiary which, apart from purposes (“its insignificant purposes”) which are capable of having no significant effect (other than in relation to incidental matters) on the extent of its activities, exists wholly for the purpose of carrying on one or more qualifying trades.
manufactured interest
means an amount— (a) which is representative of a periodical payment of interest on United Kingdom securities, and (b) which, under a contract or other arrangements for the transfer of the securities, one of the parties is required to pay to the other;
manufactured overseas dividend
means any payment which the overseas dividend manufacturer makes in discharge of that requirement.
manufactured payment
means any of the following— (a) any manufactured dividend;
market value
has the same meaning as in the 1992 Act;
material disposal
means a disposal to which this Chapter applies, otherwise than by virtue of section 758.
maximum rate commutable pension
means a pension of one-thirtieth of his relevant annual remuneration for each year of service up to a maximum of 20;
maximum rate lump sum
means a lump sum of such amount as may be determined by or under regulations made by the Board for the purposes of this paragraph and paragraph 4 below;
maximum rate non-commutable pension
means a pension of one-fortieth of his relevant annual remuneration for each year of service up to a maximum of 20,
medium-sized enterprise
means an enterprise which— but for these purposes that Annex has effect with the modifications set out in sub-paragraphs (3) to (6) of this paragraph.
member of an insurance group
has the meaning given by paragraph 11A(6).
member of the public
means a member of the public at large with whom the lender deals at arm’s length.
member of the society
has the same meaning as in Lloyd’s Act 1982.
mileage allowance payments
has the meaning given by section 197AD(2) and “passenger payments” has the meaning given by section 197AE(2).
money debt
has the same meaning as in Chapter II of Part IV of the Finance Act 1996.
Motor cycle
has the meaning given by section 185(1) of the Road Traffic Act 1988.
net turnover
has the meaning given to “turnover” by section 474(1) of that Act;
new consideration
has the same meaning as in section 254.
new policy
has the meaning given in paragraph 17 below,
new shares
means shares comprised in the new holding which were issued in respect of, or otherwise represent, shares comprised in the original holding;
non-corporate distribution
means a distribution made by a company to a recipient who is not a company.
non-exempt activities
has the meaning given by paragraph 12D(2);
non-linked liabilities
means liabilities other than liabilities in respect of benefits to be determined by reference to the value of linked assets falling within sub-paragraph (5)(a) above.
non-qualifying territory
has the meaning given by paragraph 5E above;
non-taxable sums
means donations, legacies and other sums of a similar nature which, apart from section 505(1) of this Act and section 256 of the 1992 Act, are not within the charge to tax.
normal commercial loan
means a loan of or including new consideration and—
notice of enquiry
means a notice under— (a) section 9A or 12AC of the Management Act, or (b) paragraph 24 of Schedule 18 to the Finance Act 1998;
number of employees
has the meaning given by sections 382(6) and 465(6) of that Act;
nursing home
means any establishment which exists wholly or mainly for the provision of nursing care for persons suffering from sickness, injury or infirmity or for women who are pregnant or have given birth to children;
oil
includes any mineral oil or relative hydrocarbon, as well as natural gas.
oil licence
has the same meaning as in section 555 of the Capital Allowances Act (see section 552 (1) of that Act).
old company
means a company to which section 244 of the 1970 Act applied in respect of the last accounting period ending before 17th March 1987.
on ordinary commercial terms
means a loan—
option
means a traded option or an option which is not a traded option but is an option relating to— (a) currency, shares, stock, securities or an interest rate;
Ordinary commuting
means travel between— and a place which is a permanent workplace in relation to the employment.
ordinary equity holder
means any equity holder whose entitlement on the profit distribution or the distribution on the notional winding-up does not differ according to whether or not, or the extent to which, the profits or assets distributed are referable to the non-resident company’s UK trade.
ordinary shares
means shares forming part of ordinary share capital.
original holding
has the meaning given by sub-paragraph (1) above.
outstanding capital
means the total value of all the capital interests in the company, less the value, as shown in the company’s accounts, of any advances made by the company to persons resident outside the United Kingdom and falling within paragraph (i) or paragraph (ii) of sub-paragraph (3)(b) above.
overseas dividend
means any interest, dividend or other annual payment payable in respect of any overseas securities;
overseas dividend manufacturer
has the meaning given by paragraph 4(1) below;
overseas insurer
means a person who is not resident in the United Kingdom who carries on a business which consists of or includes the effecting and carrying out of—
overseas securities
means— (a) shares, stock or other securities issued by a government or public or local authority of a territory outside the United Kingdom or by any other body of persons not resident in the United Kingdom;...
overseas tax
means tax under the law of a territory outside the United Kingdom;
overseas tax credit
means any such credit under the law of a territory outside the United Kingdom in respect of overseas tax as corresponds to a tax credit;
overseas territory
means any territory or country outside the United Kingdom;
paragraph 6C claim
has the meaning given by paragraph 6C(2) above;
parent company
means a company that—
participating company
means the grantor or any other company to which for the time being the scheme is expressed to extend.
participator
has the meaning given by section 417(1) and the definition of "control" in section 840 applies (with the necessary modifications) in relation to a company which is an unincorporated association as it applies in relation to one that is not.
partnership
includes an entity established under the law of a country or territory outside the United Kingdom of a similar character to a partnership;
passenger payments
has the meaning given by section 197AE(2).
payment
means a payment made under a scheme, being a payment made to a person carrying on a trade to which the scheme relates and not being a payment made by way of repayment of contributions;
pension
includes a gratuity or any sum payable on or in respect of death or, in the case of a pension falling within subsection (2)(g) above, ill-health, and a return of contributions with or without interest thereon or any other addition thereto;
permanent workplace
means a place which the employee regularly attends in the performance of the duties of the employment and which is not a temporary workplace;
personal relief
means relief under Chapter I of Part VII;
pleasure craft
means any ship of a kind primarily used for sport or recreation;
policy
means a policy evidencing a contract of long-term insurance, and includes any such policy issued outside the United Kingdom.
policy of life insurance
means a policy of life insurance in relation to which...
post-1986 accounting period
means an accounting period which begins on or after 1st April 1987;
post-change accounting period
means the accounting period beginning immediately after the change in the ownership of the company or, as the case may be, the relevant company.
post-commencement period
means any accounting period beginning on or after 1st January 2006— (a) which is the commencement period, or (b) which ends after the commencement period;
pre-commencement period
means any accounting period— (a) beginning on or after 1st January 2006, and (b) ending before the commencement period.
prescribed
means prescribed by regulations made by the Commissioners for Her Majesty's Revenue and Customs.
Private travel
means travel between—
products obtainable from the living animal
means— (a) the young of the animal, or (b) any other product obtainable from the animal, not being a product obtainable only by slaughtering the animal itself.
profit-related pay
means profit-related pay under whatever scheme;
profits
includes income;
property development
means the development of land— (a) by a company which has, or at any time has had, an interest in the land, and (b) with the sole or main object of realising a gain from the disposal of an interest in the land when it is developed;
Property managing subsidiary
means a qualifying subsidiary of the relevant company whose business consists wholly or mainly in the holding or managing of land or any property deriving its value from land.
Protection business
means contracts of long-term insurance where— and references to protection business include a reference to reinsurance of protection business.
provisional repayment
means a provisional repayment under paragraph 1 above;
pure protection policy
means a policy—
qualifying borrower
has the meaning given by section 376(1) to (3);
qualifying company
means the relevant company or any relevant qualifying subsidiary of that company.
qualifying creative works
means— created by the taxpayer personally or, where the trade, profession or vocation is carried on by the taxpayer in partnership, by one or more of the partners personally.
qualifying lender
has the meaning given by section 376(4)...;
qualifying office
means an office mentioned in section 2(2)(b), (c) or (d) of the Parliamentary and other Pensions Act 1987;
qualifying passenger
means a passenger who is also an employee for whom the travel is business travel.
qualifying policy
includes a policy which would be a qualifying policy apart from— (a) paragraph A1(2), B1(2), B2(2) or B3(3) of Schedule 15, or (b) paragraph 17(2)(za) of that Schedule (including as applied by paragraph 18), and • “relevant person” means a person— (a) who issues, or has issued, qualifying policies, or (b) who is, or has been, a relevant transferee in relation to qualifying policies.