Explanatory Notes

Commentary on Sections

Part 2: Double taxation relief

Chapter 2: Double taxation relief by way of credit

Section 53: Earlier years’ non-trading deficits on loan relationshipsSection 54: Non-trading debits on loan relationshipsSection 55: Current year’s non-trading deficits on loan relationships

155.These sections harmonise the credit relief regime with the loan relationships regime. They are based on sections 797(3) to (6) and 797A of ICTA.

156.As explained in the commentary on section 50, the figures calculated for the purposes of the loan relationships regimes need to be analysed for the purposes of credit relief. Sections 53 and 55 are about the allocation for those purposes of non-trading deficits. Section 54 is about the allocation for those purposes of non-trading debits.

157.In sections 53 to 55, “the period” is the period mentioned in section 42(2).