Commentary

D9.447 Unrealised interest in default

Corporate tax
Corporate tax | Commentary

D9.447 Unrealised interest in default

Corporate tax | Commentary

D9.447 Unrealised interest in default

For the treatment of transfers with unrealised interest, see D9.414.

Where the issuer of the securities has defaulted on payments of interest, the value of the interest coupons that are transferred will be reduced.

The amount of the deemed payment to the transferor (T) (see D9.414) and the amount of T's AIP to be taken into account depend on whether T himself acquired the securities with a right to receive unrealised interest. If he did not, those amounts are taken to be the value on the date of transfer of the right to receive the interest1.

Where T

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