Commentary

D2.218A Group relief surrenders—current year non-trading loan relationship deficits

Corporate tax
Corporate tax | Commentary

D2.218A Group relief surrenders—current year non-trading loan relationship deficits

Corporate tax | Commentary

D2.218A Group relief surrenders—current year non-trading loan relationship deficits

Interest paid under a loan relationship may (depending on the nature of the interest) create either:

  1.  

    (a)     a trading expense (if the interest relates to the company's trade) and create or augment a trading loss. It can be surrendered as such (see D2.217); or

  2.  

    (b)     a non-trading loan relationship debit (if the interest does not relate to the company's trade).

  3.  

    This may also be surrendered by way of group relief1.

In a similar way to trading losses and capital allowances (see D2.217 and D2.218), the surrendering company does not have

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