Commentary

D1.703 Meaning of a loan relationship

Corporate tax
Corporate tax | Commentary

D1.703 Meaning of a loan relationship

Corporate tax | Commentary

D1.703 Meaning of a loan relationship

A company has a loan relationship if:

  1.  

    •     it is either a creditor or a debtor for a money debt (see D1.704) and that debt arises from the lending of money (see MJP Media Services1 in which the Court of Appeal upheld the tribunal decision that the appellant had failed to show that there had been a lending of money for the purposes of the definition of a loan relationship)2; examples of such loan relationships are overdrafts, bank and building society loans and deposits, debentures, certificates of deposit, mortgages, gilts, company securities (including eurobonds but excluding

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