Corp Tax - Chapter 8 Flashcards
1
Q
Loan relationship examples…
A
Debentures in a company
Government Gilts
Bank Deposit account
Bank overdraft
Loan to an employee
2
Q
Loan relationship income and expenses examples:
A
- Interest payable and receivable
- Costs to issue the debt
- Debt collection costs
- Pre-loan and abortive expenses
- Profit or loss on the acquisition or disposal of an existing loan relationship
(called a related transaction) - Loans written off (known as impairments or bad debts) – result in expense in the company writing the debt off
- Release of loans –
– an expense in the company which has released the debt; and
– income in the company that has had its obligation to pay the debt
released (unless the release is part of a statutory insolvency
arrangement).
3
Q
Late Interest Payable to Participators in Close Companies
A
Accruals Basis
4
Q
When is interest deductible
A
Interest is deductible when it is paid if:
- it is payable to a participator (or their associate) in a close company; and
* it has not been paid within 12 months of the end of the accounting period;
* it has not been taxed under the loan relationship rules in the hands of the recipient
5
Q
What is a close company?
A
- Five or less people
- Not controlled by a non close company
6
Q
When is interest not taxed under LR rules
A
Tax haven countries