Loan relationships

Loan relationships guidance:

The rules comprising the corporate interest restriction are lengthy and complex. To assist the reader, this Practice Note starts with a background section and a short,...

Practice Note

A ‘loan relationship’ is defined as a money debt arising from the lending of money. However, this definition does not reflect all the types of arrangements and...

Practice Note

A ‘loan relationship’ is defined as a money debt arising from the lending of money. However, this definition does not reflect all the types of arrangements and...

Practice Note

Certain securities and contracts do not naturally fall within just one of the loan relationships regime or the derivative contracts regime. In addition, some contracts...

Practice Note

Certain securities and contracts do not naturally fall within just one of the loan relationships regime or the derivative contracts regime. In addition, some contracts...

Practice Note

The general rule is that: • the loan relationships regime forms a self-contained, exclusive, regime for the taxation of corporate debt (ie very broadly, a company's...

Practice Note

The general rule is that: • the loan relationships regime forms a self-contained, exclusive, regime for the taxation of corporate debt (ie very broadly, a company's...

Practice Note

A foundational principle of the loan relationships regime is that the profits and losses to be brought into account for corporation tax purposes on a company’s loan...

Practice Note

A foundational principle of the loan relationships regime is that the profits and losses to be brought into account for corporation tax purposes on a company’s loan...

Practice Note

A foundational principle of the loan relationships regime is that companies are taxed on their borrowing and lending activities and other forms of corporate debt on the...

Practice Note

This Practice Note considers the regime-wide, targeted anti-avoidance rule (the regime TAAR) intended to counteract loan-related tax advantages arising from relevant...

Practice Note

The general rule is that the credits (broadly, but not necessarily, profits) and debits (broadly, but not necessarily, losses) arising to a company from its corporate...

Practice Note

The general rule is that the credits (broadly, but not necessarily, profits) and debits (broadly, but not necessarily, losses) arising to a company from its corporate...

Practice Note

The rule is that the credits (broadly, but not necessarily, profits) and debits (broadly, but not necessarily, losses) arising to a company from its corporate finance...

Practice Note

The general rule is that the taxation of the credits and debits arising to a company from its loan relationships in an accounting period are those shown in its GAAP...

Practice Note

The general rule is that the taxation of the credits and debits arising to a company from its loan relationships in an accounting period are those shown in its GAAP...

Practice Note

Although, by its nature, no interest is payable on a deeply discounted security (DDS), the discount is effectively treated as if it were a form interest. The payment of...

Practice Note

FORTHCOMING CHANGE relating to transfers within an EU group: Finance Bill 2019–20 will contain provisions permitting companies to pay tax in instalments in relation to...

Practice Note

The general rule is that: • the credits (broadly, but not necessarily, profits), and • debits (broadly, but not necessarily, losses) arising to a company from its...

Practice Note

The loan relationships rules in Part 5 of the Corporation Tax Act 2009 (CTA 2009) contain certain anti-avoidance measures relating to the late payment of interest. Where...

Practice Note

The loan relationships regime provides the rules for the taxation and relief of a company’s profits and losses from its ‘loan relationships’. The rules are principally...

Practice Note

The loan relationships regime provides the rules for the taxation and relief of a company’s profits and losses arising from its ‘loan relationships’. The main body of the...

Practice Note

Although the most common type of distribution is a dividend paid by a company to its shareholders in respect of their shares (ie a distribution of accumulated profits to...

Practice Note

Although the most common type of distribution is a dividend paid by a company to its shareholders in respect of their shares (ie a distribution of accumulated profits to...

Practice Note
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