Related Commentary  Related HMRC Manuals

152(1)  This section applies where–

(a)both of the affected persons are companies, and

(b)the actual provision is provision in relation to a security issued by one of those companies (“the issuing company”).

152(2)  Section 147(1)(d) is to be read as requiring account to be taken of all factors, including–

(a)the question whether the loan would have been made at all in the absence of the special relationship,

(b)the amount which the loan would have been in the absence of the special relationship, and

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