Related Commentary  

398  Where a company sustains a loss on the exercise or disposal of a right to receive any amount, being a right to which section 56(2) applies, in a case where–

(a)if a profit had arisen from that exercise or disposal, that profit would have been chargeable to corporation tax by virtue of section 56(2), and

(b)the company is chargeable to corporation tax under Part 5 of CTA 2009 (loan relationships) in respect of interest payable on that amount,

then the amount of its loss may be set off under section 91 of CTA 2010.


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