Commentary

D1.790 Loan relationships—Imported losses

Corporate tax
Corporate tax | Commentary

D1.790 Loan relationships—Imported losses

Corporate tax | Commentary

D1.790 Loan relationships—Imported losses

Where a company accounts for a loan relationship on an amortised cost basis, no deduction is permitted for a loss on a loan relationship that is referable to a time when the loan relationship was not subject to UK tax. This will be the case where a company resident abroad becomes resident in the UK or where a foreign company trading in the UK through a permanent establishment has a loan relationship which was not held for the purposes of that permanent establishment. The legislation restricting relief does not apply where accounts are drawn up on

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