447 Exchange gains and losses on debtor relationships: loans disregarded under [Part 4 of TIOPA 2010]

Transactions not at arm's length: exchange gains and losses

447  Exchange gains and losses on debtor relationships: loans disregarded under [Part 4 of TIOPA 2010]

(1)     Subsections (2) and (3) apply if—

(a)     a company has a debtor relationship in an accounting period,

(b)     an exchange gain or loss arises in the period in respect of a liability representing the relationship, and

(c)     as a result of [section 147(3) or (5) of TIOPA 2010] (provision not at arm's length) the profits and losses of the company are calculated for tax purposes for the period

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