HZ 10What happens when election is made under section HZ 9?

1. This section applies when—

2. an originator makes an election under section HZ 9 that relates to a debt funding special purpose vehicle; and
3. immediately before the election is made, the special purpose vehicle holds a financial arrangement or an excepted financial arrangement that was transferred to the special purpose vehicle by 1 of its originators.

4. For the purposes of calculating the income tax liability of the special purpose vehicle and its originators for the income year in which the election is made and later income years (the post-disposal periods),—

5. the relevant originator is treated for the post-disposal periods as if they had acquired and held the financial arrangement or excepted financial arrangement, not the special purpose vehicle:
6. the relevant originator is treated for the post-disposal periods as if they had paid any consideration originally paid by the special purpose vehicle for or under the financial arrangement or excepted financial arrangement, and the special purpose vehicle is treated as not having paid that consideration:
7. the relevant originator is treated for the post-disposal periods as if they had received any consideration originally received by the special purpose vehicle for or under the financial arrangement or excepted financial arrangement, and the special purpose vehicle is treated as not having received that consideration:
8. the special purpose vehicle is, for the financial arrangement, a party that is not required to calculate a base price adjustment, despite section EW 29 (When calculation of base price adjustment required).

9. Section HR 10 (What happens when vehicle stops being transparent debt funding special purpose vehicle?) overrides this section.

10. Subsection (2) does not give rise to a supply of goods or services under the Goods and Services Tax Act 1985.