The loan relationships provisions for companies have been around since 1996, and it is fair to say that the legislation overall is complex. However, it is not normally difficult to identify a loan relationship for these purposes, although a recent case indicates that even this task may not be without its problems. The loan relationship legislation in FA 1996 was rewritten and is now contained in CTA 2009. It states that a company has a ‘loan relationship’ for corporation tax purposes if it is either a debtor or a creditor in respect of a money debt, and the debt arises… Read more…





