Corporation Tax Act 2009 section 478

Relevant non-lending relationships: introduction

Section 478 introduces the chapter dealing with relevant non-lending relationships and provides a guide to the key definitions, extensions of meaning, and exclusions contained in the chapter.

• The loan relationships rules in Part 5 are extended to cover certain money debts that are not loan relationships — these are called "relevant non-lending relationships"
• A relevant non-lending relationship can arise either with or without a discount element, and each type is defined separately
• The meanings of "money debt" and "interest" are broadened in certain circumstances, including where exchange gains and losses arise or where transactions are not at arm's length
• Certain debts are excluded from this chapter, notably where the profits or losses already fall within the derivative contracts or intangible fixed assets rules, or where exchange gains and losses relate to tax debts