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Loan relationship
Practical Law UK Glossary 2-107-6781 (Approx. 3 pages)
Glossary
Loan relationship
The "loan relationship" rules govern the UK corporation tax treatment of certain debt. Broadly, a company has a loan relationship if the two following conditions are met:
- There is a money debt.
- The money debt arises from a "transaction for the lending of money" (section 302(1)(b), Corporation Tax Act 2009 (CTA 2009)) or an instrument is issued by any person for the purpose of representing security for, or the rights of a creditor in respect of, the money debt (section 303(3), CTA 2009).
For further detail, see Practice note, Loan relationships.