Corporation Tax Act 2009 section 302

"Loan relationship", "creditor relationship", "debtor relationship"

Section 302 defines the key terms "loan relationship", "creditor relationship" and "debtor relationship" for the purposes of the Corporation Tax Acts.

• A company has a loan relationship where it is a creditor or debtor in respect of a money debt that arises from a lending transaction, whether or not the debt is secured
• A creditor relationship is a loan relationship where the company is the lender (i.e. it is owed the money)
• A debtor relationship is a loan relationship where the company is the borrower (i.e. it owes the money)
• The loan relationships rules also extend to various other arrangements that are treated as loan relationships, including holdings in OEICs, unit trusts and offshore funds, building society and industrial and provident society arrangements, alternative finance arrangements, shares with guaranteed returns, partnership returns, manufactured interest, repos and investment life insurance contracts