Corporation Tax Act 2009 section 481

Application of Part 5 to relevant non-lending relationships

Section 481 explains how the loan relationships rules in Part 5 of the Act are applied to relevant non-lending relationships, and identifies the specific matters for which credits and debits may be brought into account.

• The loan relationships rules apply to relevant non-lending relationships, but only in respect of specified "relevant matters" — not the full range of items that would arise under a true loan relationship.
• For non-discount debts, the relevant matters include interest, exchange gains or losses, profits from related transactions involving the right to receive interest, impairment losses or releases on unpaid business payments, reversals of such impairments, and the release of debts where a relevant deduction has been allowed.
• For discount debts, additional relevant matters include the discount itself, profits from any related transaction, impairments on the discount, and reversals of those impairments.
• If a company transfers its right to receive interest through a related transaction, the non-lending relationship continues to exist for the purpose of bringing profits from that or any subsequent related transaction into account.