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Contents

Official guidance
Business Income Manual

BIM64240 · Private Finance Initiative (PFI): interest

  • BIM64245 · Trade
  • BIM64250 · Trade: table of examples
  • BIM64255 · Trade: example 1
  • BIM64260 · Trade: example 2
  • BIM64265 · Trade: example 3
  • BIM64270 · Trade: example 4
  • BIM64275 · Trade: example 5
  • BIM64280 · Trade: example 6
  • BIM64285 · Trade: example 7
  • BIM64290 · Trade: example 8
  • BIM64295 · Non-trade
  • BIM64300 · Non-trade: table of examples
  • BIM64305 · Non-trade: example 1
  • BIM64310 · Non-trade: example 2
  • BIM64315 · Non-trade: example 3
  • BIM64320 · Non-trade: example 4
  • BIM64325 · Pre-trading
  • BIM64330 · Pre-trading: table of examples
  • BIM64335 · Pre-trading: example 1
  • BIM64340 · Pre-trading: example 2
  • BIM64345 · Pre-trading: example 3
  • BIM64350 · Pre-trading: example 4
  • BIM64355 · Pre-trading: example 5
  • BIM64360 · Pre-trading: example 6
  • BIM64365 · Private Finance Initiative (PFI): deemed premium on lease
  • BIM64370 · Private Finance Initiative (PFI): refinancing gains
  • BIM64371 · Private Finance Initiative (PFI): refinancing gains: interest
  • BIM64375 · Private Finance Initiative (PFI): capital allowances
  • BIM64380 · Private Finance Initiative (PFI): capital allowances - highway undertakings
  • BIM64385 · Private Finance Initiative (PFI): capital allowances - highway undertakings - toll roads
  • BIM64390 · Private Finance Initiative (PFI): Capital allowances - highway undertakings - right to receive sums from a relevant authority
  • BIM64395 · Private Finance Initiative (PFI): group relief
  • BIM64400 · Private Finance Initiative (PFI): group relief: trading company
  1. Private Finance Initiative (PFI): interest: contents
  2. Private Finance Initiative (PFI): interest: non-trade

BIM64295 | Private Finance Initiative (PFI): interest: non-trade

From HM Revenue & Customs · Business Income Manual

S299-S301, S320 Corporation Tax Act 2009

For Corporation Tax purposes, where a company is a party to a loan relationship otherwise than for the purposes of a trade carried on by it, interest payable under that relationship is not brought into account as an expense of any trade. Nor is it treated as an expense of a property business. It is a non-trading debit under the loan relationship legislation.

The non-trading debits and credits in respect of a loan relationship are aggregated with all other debits and credits arising from a company’s non-trading loan relationships and non-trading derivative contracts.

An overall net surplus is charged to tax as non-trading loan relationship profits. An overall net deficit, i.e. a ‘non-trading deficit’, may be relieved in a variety of ways (see CFM32040 onwards).

An interest debit in an accounting period in respect of a loan relationship is taken into account, whether posted to a fixed capital asset, a financial asset, or the profit and loss account.

Relief is normally available for Corporation Tax purposes when a non-trade interest debit is made:

  • to the profit and loss account and is not subsequently capitalised (see example 1 at BIM64305), or

  • when a non-trade interest debit is made to a finance debtor, or capitalised to a finance debtor, and is then matched against income credited to the finance debtor.

The one exception is where the non-trade interest is debited, or capitalised, to a fixed capital asset or project. Such a debit is to be brought into account for Corporation Tax purposes in the accounting period for which it is given, in the same way as a debit is given in determining the profit or loss for that period (see example 2 at BIM64310). We accept that where a PFI property is a fixed asset for tax purposes it falls within the definition of ‘fixed capital project’, whether reported as a fixed asset or a financial asset for accounting purposes (see example 3 and 4 at BIM64315 and BIM64320).

Where the company is constructing a property as part of a property business and carrying on a trade, the purpose of the loan will determine whether the interest is a trading debit, a non-trading debit, or is to be apportioned between the two.

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