SCHEDULE 7 Loan Relationships and Derivative Contracts
Finance Act 2016 (2016 c 24) | Legislation

SCHEDULE 7 Loan Relationships and Derivative Contracts

Section 49

Introductory

1

CTA 2009 is amended as follows.

Non-market loans

2

In Chapter 15 of Part 5 (loan relationships: tax avoidance), after section 446 insert—

“Non-market loans
446A Non-market loans

(1)     This section applies as respects any accounting period if—

(a)     a company has a debtor relationship in the period,

(b)     the amount recognised in the company's accounts in respect of the debt at the time the company became party to the debtor relationship was less than the transaction price,

(c)     credits in respect of the whole or part of the discount were not brought into account for the purposes of this Part, and

(d)     in a case where the creditor is a company, the non-qualifying territory condition is met.

(2)     The debits which are to be brought into account for the accounting period for the purposes of this Part by the debtor company in respect of the loan relationship are not to include debits relating to the relevant discount amount, to the extent that that amount is referable to the accounting period.

(3)     In this section “relevant discount amount†means—

(a)     in

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