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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.7 Loan relationships /Special classes of loan relationship / D1.755 Special classes of loan relationship
Commentary

D1.755 Special classes of loan relationship

Corporate tax

D1.755 Special classes of loan relationship

There are four types of loan relationship with special rules. These are discounted securities, gilt-edged securities, repo and stock lending (and similar) transactions and investment life insurance contracts. Each of these is discussed in more detail below.

Discounted securities

Discounted securities of close companies

Where a deeply discounted security is issued by a close company and the conditions detailed below are met, all the debits of the issuing company in respect of the discount (referable to the relevant period) are deferred and are brought into account for the accounting period in which the security is redeemed1. Where the security is held by a participator for only part of the relevant period, the amount deferred is restricted (on a time basis) to the debit applicable to that part period2.

The necessary conditions for this rule to apply are that:

  1. Ìý

    •ÌýÌýÌýÌý the person standing in the position of a creditor at any time in an accounting period (the 'relevant period') is a participator, an associate of a

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