What is a non-trading loan relationship?

A company will have a non-trading loan relationship if it is not a party to that loan relationship for the purposes of its trade. For example, if

it has no trade, such as an investment company, or

it has a trade, but it holds a loan relationship for investment or other non-trade purposes.

Note that a property or overseas property business is not treated as a trade for this purpose, nor is a mine or railway etc under CTA09/S39.

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