Corporation Tax Act 2009 section 294

Matters treated as loan relationships

Section 294 explains how Part 6 of the Act relates to the main loan relationships rules and ensures that references to the loan relationships Part also cover matters treated as loan relationships.

• Part 6 of the Act deals with items that are treated as loan relationships (or as rights, payments or profits under loan relationships) for some or all purposes.
• References to the main loan relationships Part (Part 5) in the Act and in other tax legislation generally include references to Part 6 as well, unless the context suggests otherwise.
• This linkage arises because the loan relationships rules are spread across two separate Parts of the Act — Part 5 (the core rules) and Part 6 (matters treated as loan relationships).
• The practical effect is that accountants applying the loan relationships regime need to consider both Parts together, as the rules in Part 6 are intended to be read as part of the same overall framework.