Commentary

D7.324 Restriction of loan relationship debits and non-trading deficits

Corporate tax
Corporate tax | Commentary

D7.324 Restriction of loan relationship debits and non-trading deficits

Corporate tax | Commentary

D7.324 Restriction of loan relationship debits and non-trading deficits

Where there has been a change in the ownership of a company with investment business resulting in a restriction of carry forward of management expenses (see D7.322), there is also a restriction on the amount of loan relationship debits and non-trading deficits which can be deducted for periods after the change1.

The loan relationship debits concerned are2:

  1.  

    (a)     a non-trading debit which is brought into charge under an amortised cost basis of accounting that:

    1.  

      (1)     because it is paid late, is not brought into account until it is paid; and

    2.  

      (2)     would otherwise have been

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