Relief for losses is available in respect of certain loans to traders. Relief is available for ‘a qualifying loan’, i.e. a loan in the case of which:
•the money lent is used by the borrower wholly for the purposes of a trade, profession or vocation (or for setting up such a trade, etc. The trade must, however, subsequently commence) carried on by him (but which does not include the lending of money);
•(for loans made before 24 January 2019) the borrower is ‘resident in the UK’ (see ¶3500); and
•the debt is not a debt on a security (a loss on which may be allowable under general rules: see ¶15050).