SCHEDULE 12 Eliminating Tax Mismatch for Certain Debt
Finance Act 2019 (2019 c 1) | Legislation

SCHEDULE 12 Eliminating Tax Mismatch for Certain Debt

Section 29

Loan relationships with qualifying link

1

After section 352A of CTA 2009 insert—

“352B Eliminating tax mismatch for loan relationships with qualifying link

(1)     This section applies if—

(a)     section 349 applies in respect of a loan relationship of a company for an accounting period (application of amortised cost basis to connected companies relationships),

(b)     the company is a party to another loan relationship (“the external loan relationshipâ€) in respect of which that section does not apply for the period,

(c)     the external loan relationship is a debtor relationship dealt with in its accounts on the basis of fair value accounting, and

(d)     the external loan relationship has a qualifying link with one or more other loan relationships of the company.

(2)     For this purpose the external loan relationship has “a qualifying link†with one or more other loan relationships of the company if—

(a)     each of those other loan

Powered by Lexis+®
 

Popular documents

LEXISNEXIS

Voluntary manslaughter

Voluntary manslaughterVoluntary manslaughterVoluntary manslaughter consists of those killings which would be murder (because the accused has the relevant mental element for murder) but which are reduced to manslaughter because of one of the three special defences (loss of control, diminished

LEXISNEXIS

Rescission of a contract

Rescission of a contractWhat is rescission of a contract?The remedy of rescission is available to a party whose consent, in entering into a contract, has been invalidated in some way:•the effect of rescinding a contract is to extinguish it and restore the parties to their pre-contractual

LEXISNEXIS

No deal Brexit—jurisdiction (UK and the Lugano Convention) [Archived]

No deal Brexit—jurisdiction (UK and the Lugano Convention) [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note has been produced in partnership with Guy Pendell, Liz Williams and Kushal Gandhi of CMS.This Practice Note covers the situation where the UK

LEXISNEXIS

Negligence—when is the duty of care breached?

Negligence—when is the duty of care breached?Having established that a duty of care exists (see Practice Note: Negligence—when does a duty of care arise?), it is then necessary to consider whether or not there has been a breach of that duty. This will depend on a number of factors outlined below and