SolvedCFM80020 | Old rules: loan relationships: quick guide to converting from FA 1996 to CTA 2009
From HM Revenue & Customs · Corporate Finance Manual
Converting from FA 1996 to CTA 2009
The table below provides a guide to certain key terms used in the guidance on the loan relationships legislation at CFM80100 onwards. These key terms are explained more fully in the guidance on the current rules.
| Subject | FA96 | CTA 2009 | Reference |
|---|---|---|---|
| Profits from loan relationships chargeable as income under this Chapter/Part | 80(1) | 295(1), S299(1) | CFM30170 |
| Priority of loan relationship rules for corporation tax purposes | 80(5) | 464(1), (2) | CFM30130 |
| Loan relationship - a money debt arising from a transaction for the lending of money | 81(1) | 302(1) | CFM31010 |
| Money debt includes an instrument issued | 81(3) | 303(3) | CFM30140 |
| Trading credits and debits brought into account as trade receipts | 82(2) | 297(2), (3) | CFM30180 |
| Non-trading credits and debits | 82 | 301 | CFM32030 |
| Profits includes profits from related transactions and capital profits | 84(1) | 293(1), (3) | CFM30170 |
| Fairly represents | 84 (1) | 307(3) | CFM33020 |
| Pre-loan relationship and abortive expenses | 84(4) | 329(1), (2) | CFM33060 |
| Meaning of ‘related transaction’ | 84(5), (6) | 304(1), (2) | CFM31120 |
| Exchange gains and losses included | 84A | 328 | CFM33010 |
| Computation in accordance with GAAP | 85A | 307(2), 313(1), 309 | CFM33070\nCFM33110 |
| Amounts recognised in determining company’s profit or loss include amounts in P&L etc | 85B | 308 | CFM33100 |
| Derecognition | 85C | 311, 312 | CFM33120 |
| Connection | 87 | 348-351, 466, 467 | CFM35170\nCFM36090 |
| Control | 87A | 472 | CFM35120 |
| Shares as debt | 91A-91G | PT6/CH7 | CFM45000 |
| - | FA96/SCH9 | - | - |
| Connected parties late interest | PARA 2 | PT5/CH8 | CFM35800 |
| Deemed debt releases on connected company impaired debts | PARA4A | 361 - 363 | CFM35430 |
| Releases of debt and insolvency | PARA 5 | 322, 323, 358, 359 | CFM33190 |
| Impaired or released consortium debt | PARA5ZA, PARA5A | PT5/CH7 | CFM35600 |
| Connected parties impairment losses | PARA6,PARA6,PARA6C | 323, 352, 354, 355, 357, 360 | CFM35310 |
| No debits from revaluation | PARA6D | 324, 325 | CFM33210 |