Explanatory Notes

Corporation Tax Act 2009

2009 CHAPTER 4

26 March 2009

Commentary on Sections

Part 5: Loan Relationships

Overview

Chapter 12: Special rules for particular kinds of securities
Overview
Section 418: Loan relationships treated differently by connected debtor and creditor

1243.This section applies where connected companies are debtor and creditor to a loan relationship which is treated as bifurcated by the debtor but not by the creditor. It is based on section 94B(1) to (6) of FA 1996. Where the debits brought into account by the debtor exceed the credits brought into account by the creditor additional credits must be brought into account by the creditor.