When have credits been ‘brought into account’ by the creditor

Condition B in CTA09/S373 means that for the creditor to bring into account the full amount of the interest for the purposes of the loan relationships legislation does not mean that the creditor must have paid corporation tax on the whole of the interest. Provided it is chargeable in principle, it does not matter if other kinds of debits, group relief etc mean that no tax is payable.

Equally, the interest will be ‘brought into account’ if the creditor company has recognised an impairment loss in respect of the interest receivable, and that loss is allowed as a loan relationships debit.