Following the enactment of the corporate loan relationship rules in FA 1996 (now found in CTA 2009, Pt. 5) providing a new and comprehensive code for corporation tax purposes for taxing and relieving interest and related payments, a further consideration in cases of non-recourse funding is whether the ‘non-recourse’ nature of the lessor’s obligations could result in its being denied relief for interest payments under the loan, under the potentially wide-ranging anti-avoidance provisions in CTA 2009, s. 441 and 442.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.