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Corporation Tax Act 2009 section 418
Loan relationships involving connected debtor and creditor where debits exceed credits
Section 418 deals with situations where connected companies are debtor and creditor under the same loan relationship, and the debtor treats the loan as bifurcated (that is, split into a loan element and a derivative element) while the creditor does not, resulting in the debtor's deductions exceeding the creditor's taxable income from the arrangement.
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