The loan relationships regime provides the rules for the taxation and relief of a company’s profits and losses arising from its ‘loan relationships’—broadly speaking, its lending and borrowing activities.
The loan relationships regime only applies to companies within the charge to UK corporation tax. The regime does not apply to individuals, nor to partnerships or limited liability partnerships (although it does apply to any corporate members of such if they are within the charge to corporation tax). For more on which entities fall within the scope of the loan relationships regime, see Practice Note: Loan relationships—what are they?—Who falls within the loan relationships regime?
The main body of the rules is found in Part 5 of the Corporation Tax Act 2009 (CTA 2009) (which is sections 292–476). Part 6 (CTA 2009, ss 477–569) contains some further provisions which deem certain kinds of transactions to be loan relationships or otherwise within the Part 5 taxing regime.
HMRC's published guidance on loan relationships can be found in its Corporate Finance Manual from CFM30000 onwards.
The loan relationships rules charge
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