Commentary

D1.1417 Corporate interest restriction—calculating tax-interest income amounts

Corporate tax
Corporate tax | Commentary

D1.1417 Corporate interest restriction—calculating tax-interest income amounts

Corporate tax | Commentary

D1.1417 Corporate interest restriction—calculating tax-interest income amounts

The list of relevant items fall into four main categories1:

  1.  

    •     relevant loan relationship credits

  2.  

    •     relevant derivative contract credits

  3.  

    •     the finance income element of a finance lease, debt factoring or similar arrangement, or a service level agreement to the extent that the agreement is accounted for as a financial liability, and

  4.  

    •     the amount is receivable from another company in consideration for the provision of a guarantee in respect of any borrowing of that other company

The credits in relation to the first three of the above categories are the mirror image

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