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Taxation (International and Other Provisions) Act 2010

Part 6: Relocation of section 337A(2) of ICTA

Overview

1316.This Part inserts section 1301A of CTA 2009.

Section 1301A of CTA 2009: Restriction of deductions for interest

1317.This new section rewrites section 337A(2)(a) of ICTA, which allows no deduction for interest other than under the loan relationships provisions. Section 337A(2)(a) of ICTA was originally proposed to be repealed by CTA 2009, but was retained as it was considered necessary for any cases where “interest” might not fall within the loan relationships provisions. It is now rewritten within Chapter 1 of Part 20 (restriction of deductions) of CTA 2009 as the more appropriate location for such a provision.

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