Loan relationships
Abortive expenditure
Accounting basis
Changes in accounting standards, HMRC's powers
Connected companies
Departures from generally accepted accounting practice
Generally accepted accounting practice
Interest rate etc. reset
Methods of accounting
Accounting for credits and debits
Adjustments on change of basis
Amortised cost basis
Amounts not fully recognised for accounting purposes
Basis of accounting
Capital expenditure
Cessation of loan relationship
Change of carrying value
Companies without GAAP-compliant accounts
Derecognition
Equity or shareholders' funds
Fair value
Fair value accounting
Imported losses
Insolvency
Opening and closing values
Release of debts
Revaluation of assets
Reversal of disallowed debits
Rules differing from generally accepted accounting practice
Writing-off government investments
Accounting methods
Amounts recognised in determining company's profit or loss
Change in accounting standards
Change of accounting basis applicable to assets or liabilities
Connected parties
Deferment of transitional adjustments
Fair value accounting
Generally
Accrual of purchase discount on loan repayable on demand
Alternative finance arrangements
Generally
Amendments of Parts 5 and 6 of CTA 2009
Anti-avoidance provisions
Double charge, avoidance of
Mandatory convertibles
Repo and stock lending arrangements
Anti-avoidance provisions, interaction with
Application of Finance Act 1996, Sch. 9, para. 13 to debit arising under FA 1996, Sch. 9, para. 19A
Assignment of contingent third-party debt claims
Assignment of right to interest under the loan to another group company
Associated companies
Authorised investment funds
Authorised investment trusts
Authorised unit trusts
Bad debts/impairment
Connected party situations
Consortium relief
Creditors in liquidation
Equity swaps
Generally
Writing-off government investment
Bad or doubtful debts
Relieved before commencement
Basic life assurance and general annuity business, non-trading deficits
Bringing amounts into account
Bringing amounts into account, trading/non-trading
Building societies
Calculation of profits and deficits
Capital expenditure, debits and credits treated as relating to
Carry back/carry forward claims
Ceasing to be party to
Ceasing to be resident in UK
Ceasing to be UK resident
Change of accounting practice
Charge to tax
As income
Non-trading profits
Chargeable assets held after commencement, transitional provisions
Chargeable gains
Collective investment schemes
General savings
Generally
Qualifying corporate bonds
Traders and their guarantors
Charitable companies, exemption for non-trading profits
Civil proceedings for recovery of property
Claims
Carry-back of non-trading deficits
Carry-forward as non-trading debit of next accounting period
Carry-forward of deficit to next accounting period
Group relief
Sideways relief
Close companies
Deeply discounted securities
Loans to participators
Close company loan to participator
Collective investment scheme
Commencement and transitional provisions
Anti-avoidance provisions etc
Generally
Sections 321, 349 and 605 of CTA 2009
Straddling accounting periods treated as split for certain purposes
Transitional adjustments relating to derivative contracts
Transitional provision relating to abolition of 'fairly represents' test
Transitional provision relating to fixed capital asset or project
Commercial rate of interest
Company is not, or has ceased to be, party to loan relationship
Company migrations
Company with investment business, restrictions on relief
Carry forward of non-trading deficit
Debits to be brought into account
Connected companies
Amortised cost basis, application
Beginning to be connected
Ceasing to be connected
Close company loans to participators
Corporate rescue exception
Debt-for-debt exception
Deemed debt releases on impaired debts
Deeply discounted securities
Equity-for-debt exception
Exclusion of credits on release or reversal of impairments
Exclusion of debits for impaired or released debts
Generally
Late interest
Meaning
Occupational pension schemes, trustees
Related transactions, disregard of
Connected parties
Connected party situations
Ceasing to be connected
Debits exceeding credits
Impairment debts and impairment losses
Consortium relief, bad debts/impairment
Contracts for financial futures, transactions by insurance companies
Controlled foreign companies
Convertible securities
Corporation tax
Counteracting effect of avoidance arrangements
Credit not taxable on release of liability
Credit unions
Creditor relationship, meaning
Credits and debits brought into account
Accounting bases
Adjustments on change of accounting basis
Amounts recognised in determining profit or loss
Companies without GAAP-compliant accounts
Disregard of pre-2005 disallowed debits
General principles
Generally
Overseas sovereign debts
Reversal of debits, restriction
Rules differing from generally accepted accounting practice
Cross-border transfers of business and mergers
DCC holdings
De-recognised for accounting purposes
Debit not arising from derivative contract
Debit not reflecting fair representation of loss from transactions
Debit relating to 'tracker shares' linked to in the money swap receipts
Debit representing cost of shares in respect of loan relationship with a subsidiary
Debits and credits brought into account
Debits and credits brought into account, creditor in liquidation
Debt capping rules, worldwide groups
Debtor relationship, meaning
Deductible debit
Deduction of tax at source
Deemed release of liability
Deep discount securities
Deep gain securities
Generally
Qualifying indexed securities
Deeply discounted securities
Accounting periods pre-1 April 2007
Close companies
Connected companies
Partnerships
Persons indirectly standing in position of creditor
Pre-1 October 2002
Derecognition
Derivative contracts
Derivatives
Connected debtor and creditor, debits exceeding credits
Embedded derivatives
Discounted securities
Chargeable gains
Generally
Disguised interest
Excluded shares
Exclusion where arrangement has no tax avoidance motive
Exclusion where return otherwise taxable
Generally
Regarded as profit from
Shares accounted for as liabilities
Disguised interest rules
Controlled foreign companies
Generally
Disposals for consideration not fully recognised
Disregard of foreign tax referable to interest under
Generally
Repos, exception for
Stock lending, exception for
Distributions
Double taxation relief
Effect of assignment on recognition of loan in accounts of assignor company
Embedded derivatives
Embedded rights and liabilities to financial or equity instruments
European company (SE)
European cross-border mergers
European cross-border transfers of business
Exchange gains and losses
Expenses
Fair representation of profits
Financing costs and income
Financing costs and income of group companies
Floating rate securities
Foreign exchange gains and losses
Funding bonds
GAAP-compliant accounting treatment
Generally
Gilt-edged securities
Index-linked pre-1 January 2005
Low-coupon gilts
Strips
Group mismatch schemes
Controlled foreign companies
Economic profits and losses, meaning
Finance arrangements
Foreign companies and foreign permanent establishments
Generally
Group, meaning
Losses and profits to be disregarded
Meaning
Provisions treated as of no effect
Relevant tax advantage, meaning
Repos or quasi-repos
Scheme group, meaning
Scheme loss, meaning
Scheme period, meaning
Scheme profit, meaning
Scheme, meaning
Tax capacity assumption
Trading income
Group of companies, novation of liabilities
Group relief
Bad debts/impairment
Generally
Group relief, impaired or released consortium debts
Accounting periods
Carry forward of claims where no net consortium debits
Credit for release brought into account on amortised cost basis
Generally
Interpretation
Reduction of claims where earlier net consortium debits
Reduction of credits exceeding impairment losses
Reduction of loss debits
Groups
Intra-group transactions
Mismatch rules
Groups of companies, restriction of deduction for financing costs and income
Groups of companies, transfers between
Fair value accounting
Generally
Notional carrying value
Transferee leaving group
Imported losses
Imputed interest
Incidental costs of loan finance
Income stream transfers
Industrial assurance business
Insolvency, corporate rescue etc
Insurance companies
Basic life assurance and general annuity business
Generally
I - E basis
Loss relief
Inter-company transactions, deductions
Interest coupons recognised in accounts during repo term
Interest on overpaid/underpaid tax
Interest payable, deferral
Interest under, meaning
Interpretation of section 455B
Interpretation of section 698B
Intra group forward subscription agreement
Investment companies functional currency
Investment life insurance contracts
Investment life insurance contracts, gains on
Investment trusts
Creditor relationships, accounting methods
Generally
Judgments, interest on
Late interest rules
Connected companies
Deduction of tax
Occupational pension scheme trustees
Late paid interest
Legal and accounting concepts
Life insurance contracts, gains on
Limits on/reduction of credit for foreign tax
Current year's non-trading deficits
Deductions, allocation of
Earlier years' non-trading deficits
Generally
Non-trading debits
Liquidation, creditors in
Lloyd's underwriters
Mandatory convertibles
Manufactured dividends and interest
Generally
Overseas securities
Manufactured interest
Matched, meaning
Matters in respect of which amounts are to be brought into account
Matters treated as
Meaning
Migrations
Money debt, meaning
Money debts
Discounts
Exchange gains and losses
Generally
Impairment losses
Imputed interest on transfer pricing adjustments
Interest on judgments
Interest on tax
Meaning
Non-lending relationships
No profit recognised in accounts
Non-lending relationships
Amounts to be brought into account
Discounts on disposals pre-22 March 2006
Exchange gains and losses treated as money debts
Exclusions
Generally
Interest, meaning
Involving discounts
Money debt, meaning
Not involving discounts
Relevant matters
Non-trading
Non-trading deficits
Brought into account
Calculation
Generally
Set off deficit against profits of deficit period
Non-trading deficits, relief
Non-trading profits
Calculation
Carry forward of unrelieved deficit
Charge to tax
Non-UK resident ceasing to hold loan relationship for permanent establishment
Notional closing values of relevant assets
Notional interest
Offshore funds
Oil extraction activities, calculation of profits
Open-ended investment companies
Generally
Options
Overpaid/underpaid tax, interest on
Overview
Partnerships
Involving companies
Structured finance arrangements
Partnerships involving companies
Party to loan relationships represented by gilts
Payment under, meaning
Payments subject to deduction of tax
Pre-commencement, adjustments in respect of
Pre-trading expenditure
Price of shares calculated by reference to inter-company loan relationship
Profits and gains, bringing amounts into account
Profits or losses, construction of references to
Profits realised on loan notes, appropriation to share premium account
Proper application of provisions to the assignee company
Provision of shares for transfer pricing purposes
Purposes of trade, meaning
Qualifying corporate bonds
Generally
Transitional provisions
Qualifying indexed securities
Related transaction, meaning
Related transactions
Release of loan, covenants in loan agreement
Relevant non-lending relationships
Reorganisations
Reorganisations, issue of new securities
Disposal at notional carrying value
Fair value accounting
Generally
Repairing balance sheet of group company
Repeal of certain provisions relating to late interest etc
Repeal of uncommenced repeal provisions
Repo arrangements
Repo over interest coupons
Repos
Reserves
Reset interest etc.
Rights or liabilities under, meaning
Risk transfer schemes
Generally
Sale and repurchase of gilts, claim for non-trading deficit
Sale and repurchase of securities
Set-off on non-trade deficits
Shares
Accounted for as liabilities
Beginning/ceasing to be treated as
Guaranteed returns (pre-22 April 2009)
Outstanding third party obligations
Pre-22 April 2009
Transitional rules, commencement of shares as debt legislation
Shares accounted for as liabilities
Becoming or ceasing to be shares
Conditions shares must meet to be a share
Excepted shares
Generally
Rights under creditor relationship
Unallowable purpose
Shares with guaranteed returns
Amounts to be brought into account
Ceasing to be treated as
Generally
Non-qualifying shares
Outstanding third party obligations
Shari'a compliant financing arrangements
Shari'a law compliant arrangements
Sovereign debts
Stock lending
Stock lending transactions
Structured finance arrangements
Generally
Substantial modification
Cases where credits not required to be brought into account
Swap agreements, qualifying payments/allocation issue/unallowable purpose issue
Tax avoidance
Connected parties
Control, meaning
Definitions
Disposals for consideration not fully recognised by accounting practice
European cross-border mergers
European cross-border transfer of business
Exchange gains and losses, transactions not at arm's length
Financial traders, creditors
Generally
Insurance companies, creditors
Non-trading deficits
Partnerships, connected parties
Priority rules
Resetting interest rates (reset bonds), fair value accounting
Tax relief schemes, restriction of interest relief
Transactions not at arm's length
Unallowable purposes
Tax mismatch schemes
Economic profits and losses, meaning
Generally
Losses and profits to be disregarded
Meaning
Priority
Relevant tax advantage/disadvantage, meaning
Scheme loss/profit, meaning
Scheme period, meaning
Scheme, meaning
Tax capacity assumption
Thin capitalisation
Trade, meaning
Trading
Transaction for the lending of money
Transactions for the lending of money, meaning
Transactions not at an arm's length
Transfer of contingent debt asset
Transfer of income streams
Transfer pricing adjustments
Transfer pricing rules applied to issue price of tracker shares
Transitional adjustments relating to loan relationships
Transitional provisions and savings
Transport transfer schemes
Treasury stock 2008–12 not redeemed pre-6 April 2009
Unallowable purposes
Unit trusts
Generally
Value of the shares income of the share recipient
Venture capital trusts
Winding up or administration
Worldwide debt cap
Writing-off government investment
