SCHEDULES

SCHEDULE 15Tax treatment of financing costs and income

Part 7“Financing expense amount” and “financing income amount”

Stranded management expenses in non-trading loan relationships: financing income

66(1)This paragraph applies where—

(a)under paragraph 65, the relevant amount is treated is not being a financing expense amount of company A, and

(b)apart from this paragraph, the relevant amount is a financing income amount of company B by virtue of meeting condition A in paragraph 55.

(2)The relevant amount is treated as not being a financing income amount of company B.

(3)In this paragraph “company A” and “company B” have the same meanings as in paragraph 65.