Commentary

D1.707 Loan relationships—Interaction with other legislation

Corporate tax
Corporate tax | Commentary

D1.707 Loan relationships—Interaction with other legislation

Corporate tax | Commentary

D1.707 Loan relationships—Interaction with other legislation

Subject to any express provision to the contrary, any amount brought into the loan relationships computation is not to be brought into account for corporation tax under any other provision1.

Derivative contracts

An amount which is brought into account under the loan relationship regime cannot be brought into account under the derivative contracts regime2.

This rule does not apply, however, where in a company's accounts a loan relationship is bifurcated into a host contract (which is taxed under the provisions of the loan relationships legislation) and an embedded derivative (which is treated as a relevant contract for the purposes of the derivative contracts legislation and is only taxable under that legislation (see D1.723))3.

In certain cases any profits or losses arising in respect of the embedded derivative are treated as giving rise to chargeable gains or allowable losses on the basis in which the profits or losses arising in

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial