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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.8 Derivative contracts /Taxation treatment of debits and credits / D1.896 Contracts with non-residents
Commentary

D1.896 Contracts with non-residents

Corporate tax

There is a special rule which applies where a company is a party to a derivative contract and the other party is not resident in the UK and the contract provides for notional payments of interest, eg on an interest rate swap.

In such a case, the company is unable to obtain tax relief for the debits in respect of notional interest payments payable by it under the terms of the contract

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Web page updated on 17 Mar 2025 16:04