Commentary

C3.711 Relief for losses on loans made before 17 April 1998

Capital gains tax
Capital gains tax | Commentary

C3.711 Relief for losses on loans made before 17 April 1998

Capital gains tax | Commentary

Qualifying corporate bonds

C3.711 Relief for losses on loans made before 17 April 1998

These provisions no longer apply for the purposes of corporation tax following the introduction of the loan relationship regime (see Division D1.7)1. Furthermore, the relief was repealed for capital gains tax in relation to loans made after 16 March 19982.

The relief under TCGA 1992, s 253 for losses on loans to traders, described in C3.701–C3.705, does not apply to a loan which is a debt on a security3, and so does not apply to a loss in respect of a qualifying corporate bond4. However, a

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