Corporate debt ― overview

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

This guidance note provides an introduction to the provisions governing the taxation of debt for UK companies and also provides links to more detailed guidance notes dealing with those provisions.

The taxation of corporate debt in the UK is complex. There are several different sets of rules governing the amount and timing of tax deductions available for interest and other amounts relating to corporate debt. These include:

•
the loan relationships regime
•
the corporate interest restriction (CIR) rules
•
transfer pricing and thin capitalisation requirements
•
a range of associated anti-avoidance measures ― it should be noted that there are regime anti-avoidance rules (RAARs) in CTA 2009, ss 455B–455D and related sections for loan relationships and in TIOPA 2010, s 461 applicable to the CIR

It should also be remembered that payments of interest by a UK company on all liabilities capable of remaining outstanding for more than one year are subject to withholding tax, unless they are expressly exempt or qualify for relief.

Loan relationships

In most instances, a company’s financing costs and

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