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Contents

Official guidance
Corporate Finance Manual

CFM96200 · Interest restriction: related parties

  • CFM96210 · Overview
  • CFM96220 · General rule
  • CFM96230 · Meaning of 25% investment
  • CFM96240 · 25% investment - attribution of rights and interests: connected persons
  • CFM96250 · 25% investment - attribution of rights and interests: persons acting together
  • CFM96260 · 25% investment - attribution of rights and interests: qualifying arrangement
  • CFM96270 · Liabilities guaranteed by a related party
  • CFM96271 · Financial assistance
  • CFM96275 · Liabilities where a related party indirectly stands as a creditor
  • CFM96280 · Holdings of debt and equity in the same proportions
  • CFM96290 · Where unrelated parties hold at least 50% of the same debt
  • CFM96300 · Where unrelated parties hold at least 50% of debt with the same rights: examples
  • CFM96310 · Debt restructuring
  • CFM96320 · Ordinary independent financing arrangements by banks and others
  • CFM96330 · Loans made by relevant public bodies
  • CFM96340 · Finance leases granted before 1 April 2017
  1. Interest restriction: related parties
  2. Interest restriction: related parties: finance leases granted before 1 April 2017

CFM96340 | Interest restriction: related parties: finance leases granted before 1 April 2017

From HM Revenue & Customs · Corporate Finance Manual

TIOPA10/S472

There is a specific grandfathering provision which applies where an asset is leased by a person (A) to another (B) under a lease which is granted before 1 April 2017 and which is a finance lease.

Where this is the case, A and B are treated as if they were not related parties in relation to the lease.

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