There are special rules governing the taxation treatment of certain kinds of interest and discount on money debts which do not arise from a loan relationship because they do not arise from the lending of money1.
Typical examples are late payments for goods and services, interest on judgment debts, interest paid to and by tax authorities and notional interest under the transfer pricing rules (Division B4.1)2.
These provisions do not apply to a debt in respect of which profits and losses (if any) fall to be brought into account under the derivative contracts or intangible fixed assets legislation; see Divisions D1.6, D1.83.
Interest
A company has a 'money debt not arising from the lending of money' where it:
- Ìý
•ÌýÌýÌýÌý stands in the position of a debtor or creditor as respects a money debt which does not arise from the lending of money and on which interest is payable to or by the company or in relation to which exchange gains or losses (see below) arise to the company4
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Web page updated on 17 Mar 2025 16:26