Commentary

D7.5132 Taxation of PHI—loan relationships

Corporate tax
Corporate tax | Commentary

D7.5132 Taxation of PHI—loan relationships

Corporate tax | Commentary

D7.5132 Taxation of PHI—loan relationships

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

Because PHI is taxed on a trading basis, the special rules for loan relationships applicable to BLAGAB or life insurance business generally do not apply so that debits, including interest payable, or credits on any loan relationships referable to PHI will be taxed as part of the profits of that trade.

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