Finance Act 2015


What changes were made?

FA15/S25 limited the categories of connection to which the late interest rules applies. It also made a similar limitation to the deeply discounted security rules at CTA09/S406-S412.

The late paid interest and deeply discounted security rules were originally introduced to counter tax asymmetries between the lender and borrower to a loan. However, these provisions have been deliberately exploited by some companies to increase the amount of tax relief they can obtain for interest expense.

The original categories of connection, were:

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