Related Commentary  Related HMRC Manuals

384A(1)  Relief is not to be given under this Chapter for interest paid by a person on a loan if–

(a)the loan is made to the person (“the borrower”) as part of arrangements which appear very likely to produce a post-tax advantage, and

(b)the arrangements seem to have been designed to reduce any income tax or capital gains tax to which the borrower (or any person whose circumstances are like those of the borrower) would be liable apart from the arrangements.

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