Commentary

D1.735 Loan relationships—Permanent as equity loans

Corporate tax
Corporate tax | Commentary

D1.735 Loan relationships—Permanent as equity loans

Corporate tax | Commentary

D1.735 Loan relationships—Permanent as equity loans

For accounting periods beginning before 1 January 2015 where a company prepared its accounts in accordance with UK generally accepted accounting practice and it did not adopt FRS 26 (and thus FRS 23), under Statement of Standard Accounting Practice (SSAP) 20 it was possible for the company to take exchange movements on a permanent as equity creditor loan relationship to reserves in its accounts, or to translate such loans using an historic exchange rate such that no exchange movements arose on the loan. Such treatment might have been adopted where the creditor loan relationship was being used as a means of providing long term funding to an overseas subsidiary as an alternative to providing funding in the form of share capital. This could be because it was considered easier to repatriate funding in the form of debt. As noted at D1.731, any exchange

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