[438 Exemption for interest payable to third parties etc]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Exemption and related provision]

[438  Exemption for interest payable to third parties etc]

[(1)     Amounts that arise to a qualifying infrastructure company in a relevant accounting period are not to be regarded for the purposes of this Part as tax-interest expense amounts of the company so far as they qualify as exempt amounts in that period (see subsections (2) and (3)).

(2)     An amount qualifies as an exempt amount so far as it is attributable, on a just and reasonable apportionment, to the times in the relevant accounting period when—

(a)     each creditor in relation to the amount is within subsection (3) or the amount is in respect of a qualifying old loan relationship (see section 439), and

(b)     the recourse of each creditor in relation to the amount is limited to relevant

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