SCHEDULE 12 Eliminating Tax Mismatch for Certain Debt
Finance Act 2019 (2019 c 1) | Legislation

SCHEDULE 12 Eliminating Tax Mismatch for Certain Debt

Section 29

Loan relationships with qualifying link

1

After section 352A of CTA 2009 insert—

“352B Eliminating tax mismatch for loan relationships with qualifying link

(1)     This section applies if—

(a)     section 349 applies in respect of a loan relationship of a company for an accounting period (application of amortised cost basis to connected companies relationships),

(b)     the company is a party to another loan relationship (“the external loan relationship”) in respect of which that section does not apply for the period,

(c)     the external loan relationship is a debtor relationship dealt with in its accounts on the basis of fair value accounting, and

(d)     the external loan relationship has a qualifying link with one or more other loan relationships of the company.

(2)     For this purpose the external loan relationship has “a qualifying link” with one or more other loan relationships of the company if—

(a)     each of those other loan

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