Loan relationships—late-paid interest


Published by a ³ÉÈËÓ°Òô Tax expert
Practice notes

Loan relationships—late-paid interest


Published by a ³ÉÈËÓ°Òô Tax expert

Practice notes
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FORTHCOMING CHANGE: At Autumn Budget 2024, the Labour government confirmed that it will proceed with the former Conservative administration's plans to abolish the remittance basis of taxation for non-UK domiciled individuals and replace it with a residence-based regime, to commence on 6 April 2025. The government also confirmed its intention to move to a residence-based regime for inheritance tax. The changes will also affect the Rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief. For information on these changes, including draft legislation published with Autumn Budget 2024, see Practice Note: The abolition of the remittance basis of taxation from 2025–26, News Analysis: Autumn Budget 2024—Private Client analysis—International, News Analysis: Autumn Budget 2024—reforming the taxation of non-doms, Autumn Budget 2024 (paras 2.56 and 5.51), OOTLAR (para 1.3) and TIIN: Reforming the taxation of non-UK domiciled individuals..

The Loan relationships rules in Part 5 of the Corporation Tax Act 2009 (CTA 2009) contain a set of Anti-avoidance provisions which relate to the late payment of interest. Where these provisions (the late-paid

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Jurisdiction(s):
United Kingdom
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Key definition:
Loan relationships rules definition
What does Loan relationships rules mean?

A self-contained regime for the taxation of corporate debt. It set out the rules for taxing the profits and relieving the losses (including interest and expenses) arising from a company's lending and borrowing activities.

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