Commentary

D1.748 Loan relationships—Cessation of UK residence

Corporate tax
Corporate tax | Commentary

D1.748 Loan relationships—Cessation of UK residence

Corporate tax | Commentary

D1.748 Loan relationships—Cessation of UK residence

Where a company ceases to be resident in the UK, it is deemed to have disposed of and re-acquired at a fair value the assets and liabilities representing its loan relationships1. This rule does not apply if the asset or liability continues to be held by the company for the purposes of a UK permanent establishment, or for times on or after 1 January 2020, where the company remains a party to the loan relationship for the purposes of its trade of dealing in or developing UK land, for the purposes of its UK

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