7.4.1 The loan relationship rules

For corporate landlords, the tax treatment of their borrowing costs is governed by the loan relationship rules. These rules form a comprehensive code which governs all corporate transactions relating to the ‘lending of money’. In particular, a company has a loan relationship if the following conditions are satisfied:

the company stands in the position of a creditor or debtor as respects any money debt; and

the debt arises from a transaction for the lending of money.

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