Commentary

D8.114 Interest distributions and deficits

Corporate tax
Corporate tax | Commentary

D8.114 Interest distributions and deficits

Corporate tax | Commentary

D8.114 Interest distributions and deficits

For accounting periods commencing on or after 26 March 2015, if an authorised investment fund makes an interest distribution, the amount that can be deducted for that accounting period cannot exceed an amount that would reduce its total chargeable profits to a level below that of its property income1 for that accounting period2. The effect of this is to charge the authorised investment fund to corporation tax on property income received and ensure the tax due is not avoided by payment of such income offshore as an interest distribution.

An interest distribution is treated as if

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