Commentary

D7.822 Treatment of interest and qualifying charitable donations

Corporate tax
Corporate tax | Commentary

D7.822 Treatment of interest and qualifying charitable donations

Corporate tax | Commentary

D7.822 Treatment of interest and qualifying charitable donations

Liabilities in respect of core capital deferred shares (CCDS) issued by building societies do not fall within the loan relationship regime1 and are taxed as dividends; see D7.803.

However a liability to pay dividends and interest in respect of other shares in, deposits with or loans to a building society is treated as a liability arising under a loan relationship of the society2, (see Division D1.7) and is dealt with for the purposes of corporation tax as follows:

  1.  

    (a)     dividends and interest accrued as payable in a society's accounts are allowable as a

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