Corporation Tax Act 2009 section 440

Overview of Chapter

Section 440 provides an overview of the anti-avoidance rules that apply to loan relationships, setting out the topics covered by the various provisions within the chapter.

• The chapter brings together all the anti-avoidance rules relevant to loan relationships in one place, covering areas such as unallowable purposes, non-arm's length transactions, connected party benefits, and interest rate manipulation.
• Specific rules address situations where loan relationship debits or credits arise from transactions not conducted at arm's length, with separate treatment for exchange gains and losses.
• Further provisions target schemes involving connected parties benefiting from creditor relationships, the resetting of interest rates to gain tax advantages, and debits from derecognising creditor relationships.
• A general anti-avoidance rule for loan relationships allows HMRC to counteract the effects of tax avoidance arrangements that produce results inconsistent with the principles of the loan relationships legislation.