EIM47140 | Paras 25 and 26: loan charge relevant step: exclusion: commercial transactions

Schedule 11 F(No 2)A 2017

Para 25 provides for an exclusion from the 2019 loan charge where the loan is made by a third party on ordinary commercial terms and the provisions of section 554F(1)(a) and (b) apply – see EIM45025.

The exclusion does not apply if there is a connection between the relevant step and a tax avoidance arrangement.