Commentary

D1.896 Contracts with non-residents

Corporate tax
Corporate tax | Commentary

D1.896 Contracts with non-residents

Corporate tax | Commentary

D1.896 Contracts with non-residents

There is a special rule which applies where a company is a party to a derivative contract and the other party is not resident in the UK and the contract provides for notional payments of interest, eg on an interest rate swap.

In such a case, the company is unable to obtain tax relief for the debits in respect of notional interest payments payable by it under the terms of the contract to the extent that, on a cumulative basis, these exceed the amount of the credits in respect of notional interest payable to the company under

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