Related Commentary  Related HMRC Manuals

187(1)  Subsection (6) applies if the following conditions are met.

187(2)  Condition A is that interest is paid by any person under the actual provision.

187(3)  Condition B is that section 147(3) or (5) applies in relation to the actual provision.

187(4)  Condition C is–

(a)that the amount (“ALINT”) of interest that would have been payable under the arm's length provision is less than the amount of interest paid under the actual provision, or

(b)that there would not have been any interest payable under the arm's length provision (so that ALINT is nil).

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