Taxation (International and Other Provisions) Act 2010 section 383

Relevant loan relationship debits

Section 383 defines "relevant loan relationship debits" for the purpose of calculating a company's tax-interest expense amounts under the corporate interest restriction rules.

  • A relevant loan relationship debit is a debit brought into account for corporation tax purposes under the loan relationship rules, whether the loan relates to a trade or is a non-trading loan relationship.
  • The debit must be one that is, or would be (were it not for the corporate interest restriction rules), recognised for corporation tax.
  • Debits relating to foreign exchange losses are excluded from the definition and do not count as relevant loan relationship debits.
  • Debits relating to impairment losses are also excluded from the definition.

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