D2.218A Group Relief Surrenders—Current Year Non-Trading Loan Relationship Deficits

Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.2 Group relief for current year and carried forward losses /Group relief—calculation for group members / D2.218A Group relief surrenders—current year non-trading loan relationship deficits

Commentary

Corporate tax

Interest paid under a loan relationship may (depending on the nature of the interest) create either:

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•�� a trading expense (if the interest relates to the company's trade), or a trading loss (or augment such

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I7.333A Companies and replacement APR property

C1.106 Allowable capital losses

D1.8101 Groups of companies

C2.1020 Employment-related securities options and capital gains

E6.303A Domicile of origin

C1.213 Liability to tax on chargeable gains—trustees in bankruptcy

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