Periods ending before 1 April 2017

Where there are profits from qualifying loan relationships (‘leftover profits’) which are not exempt under the full or 75 per cent exemptions (see ¶769-160 and ¶769-190 respectively), exemption may be possible under the matched interest rule.

The matched interest rule refers to terms from the worldwide debt cap rules, commentary on which can be found at ¶717-560ff. A number of modifications are made to the worldwide debt cap rules by TIOPA 2010, s. 371IE(6B)–(9) for the purposes of the matched interest rule only, including with regard to banking or insurance business.

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