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This Checklist details the key direct and indirect tax issues that a corporate borrower within the charge to UK corporation tax (a UK corporate borrower) should consider both before entering into a loan and throughout the term of a loan. It is intended to be used as a Checklist for a tax adviser of a UK corporate borrower and includes a brief description of the relevant tax issues and provides space for the tax adviser to make notes.

This Checklist assumes that:

1. •

   the borrower is a company within the charge to UK corporation tax in respect of the loan, ie it is either a UK tax resident company or a non-UK tax resident company for which the loan is attributable to its UK permanent establishment (a UK PE) or attributable to the non-UK resident company's trade of dealing in or developing UK land, and

2. •

   the borrower and the lender are unconnected parties acting at arm's length

It applies both to UK corporate borrowers in a bilateral loan as well as in a syndicated