Commentary

D1.704 Loan relationships—meaning of a money debt

Corporate tax
Corporate tax | Commentary

D1.704 Loan relationships—meaning of a money debt

Corporate tax | Commentary

D1.704 Loan relationships—meaning of a money debt

A money debt is defined as a debt which1:

  1.  

    •     falls to be settled by:

    1.  

      –     the payment of money. Money in its usual meaning includes currencies other than sterling (see Explanatory Note 1051 to the Corporation Tax Act 2009)

    2.  

      –     the transfer of a right which is itself a money debt, eg a company security2. Where a company held a security immediately before 22 March 2006 which became a creditor loan relationship on that date and immediately before that date the asset was a chargeable asset, the company was deemed to have disposed of the asset immediately before 22 March 2006 at its fair value (as determined for the purposes of CTA 2009, s 313(6)) and the resulting chargeable gain or allowable loss is held over until the company ceases to be a party to the loan relationship3

    3.  

      –     the issue or transfer of shares in a company. This particular provision was inserted to ensure that amounts

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