Part 2

Income tax, corporation tax and capital gains tax

Anti-avoidance provisions

Loan relationships involving connected debtor and creditor
29
1
In section 418 of CTA 2009 (loan relationships involving connected debtor and creditor where debits exceed credits), in subsection (2), after “creditor company” insert
“ or any company connected with it ”
.
2
In section 419 of that Act (section 418: supplementary), after subsection (6) insert—
6A
References in section 418 to a company bringing debits or credits into account under or for the purposes of this Part include bringing debits or credits into account under or for the purposes of this Part in determining the chargeable profits of the company (or in determining that there were no such profits) for the purposes of Chapter 4 of Part 17 of ICTA (controlled foreign companies).
3
The amendments made by this section have effect in relation to loan relationships to which a company is a party (or to which it is treated as a party under section 418(6A) of CTA 2009) on or after 6 December 2010.
4
But amounts are to continue to be brought into account for the purposes of Part 5 of CTA 2009 disregarding those amendments if the amounts relate to a time before that day.
S. 29 repealed (with effect in accordance with Sch. 5 para. 7(3)(4) of the repealing Act) by Finance Act 2011 (c. 11), s. 30, Sch. 5 paras. 6(1)(3), 7(2)(e)