451 Exception to section 449 where loan exceeds arm's length amount
Corporation Tax Act 2009 (2009 c 4) | Legislation

451  Exception to section 449 where loan exceeds arm's length amount

(1)     Section 449 does not apply if the circumstances are such that, had the parties to the relevant transaction been dealing at arm's length, the amount of the loan would have been an amount (“the arm's length amount”) greater than nil, but less than its actual amount.

(2)     Accordingly, an exchange gain or loss which arises in the

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