Section 29

LOAN RELATIONSHIPS WITH QUALIFYING LINK

1  After section 352A of CTA 2009 insert–

352B  

“Eliminating tax mismatch for loan relationships with qualifying link

352B(1)  This section applies if–

(a)section 349 applies in respect of a loan relationship of a company for an accounting period (application of amortised cost basis to connected companies relationships),

(b)the company is a party to another loan relationship (“the external loan relationship”) in respect of which that section does not apply for the period,

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