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[F1Part 10]U.K.[F1Corporate interest restriction]

Textual Amendments

F1Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1, 10(1)(2)(a)(3) (with Sch. 5 paras. 27, 32-34)

Modifications etc. (not altering text)

C1Pt. 10 excluded by 2010 c. 4, s. 937NA (as inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 7)

C2Pt. 10 excluded by 2010 c. 4, s. 938V(d) (as substituted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 9)

C3Pt. 10 excluded by 2010 c. 4, s. 938N(e) (as substituted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 8)

[F1CHAPTER 3]U.K.[F1Tax-interest amounts]

[F1Tax-interest expense and income amounts: basic rules]U.K.

[F1383Relevant loan relationship debitsU.K.

(1)This section applies for the purposes of section 382.

(2)An amount is a “relevant loan relationship debit” if—

(a)it is a debit that is (or apart from this Part would be) brought into account for the purposes of corporation tax in respect of a loan relationship under—

(i)Part 3 of CTA 2009 as a result of section 297 of that Act (loan relationships for purposes of trade), or

(ii)Part 5 of that Act (other loan relationships), and

(b)is not an excluded debit.

(3)A debit is “excluded” for the purposes of subsection (2)(b) if—

(a)it is in respect of an exchange loss (within the meaning of Parts 5 and 6 of CTA 2009), or

(b)it is in respect of an impairment loss.]