Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 322: Stranded deficits in non-trading loan relationships: financing expense

606.This section deals with stranded deficits in non-trading loan relationships from the perspective of the company incurring the financing expense and prevents a financing expense which meets condition A in section 313 from being treated as such. It is based on paragraph 63 of Schedule 15 to FA 2009.

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