Related Commentary  Related HMRC Manuals

447(1)  Subsections (2) and (3) apply if–

(a)a company has a debtor relationship in an accounting period,

(b)an exchange gain or loss arises in the period in respect of a liability representing the relationship, and

(c)as a result of section 147(3) or (5) of TIOPA 2010 (provision not at arm's length) the profits and losses of the company are calculated for tax purposes for the period as if–

(i)the loan had not been made, or

(ii)part of the loan had not been made.

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