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Official guidance
Savings and Investment Manual

SAIM10000 · Relief for interest paid: overview and contents

  • SAIM10010 · Relief for interest paid: introduction
  • SAIM10020 · Relief for interest paid: general conditions
  • SAIM10030 · Relief for interest paid: general conditions: the claimant
  • SAIM10040 · Relief for interest paid: general conditions: joint loans: examples
  • SAIM10050 · Relief for interest paid: certificates from lenders
  • SAIM10060 · Relief for interest paid: interest in excess of a reasonable commercial rate
  • SAIM10070 · Relief for interest paid: interest in excess of a reasonable commercial rate: examples
  • SAIM10080 · Relief for interest paid: interest relieved on a paid basis
  • SAIM10090 · Relief for interest paid: reasonable commercial rate
  • SAIM10100 · Relief for interest paid: arrangements minimising risk to borrower
  • SAIM10110 · Relief for interest paid: arrangements minimising risk to borrower: definitions
  • SAIM10120 · Relief for interest paid: arrangements minimising risk to borrower: arrangements producing a broadly compensatory amount
  • SAIM10130 · Relief for interest paid: arrangements minimising risk to borrower: examples
  • SAIM10200 · Relief for interest paid: loans to buy plant or machinery
  • SAIM10210 · Relief for interest paid: interest in a close company
  • SAIM10220 · Relief for interest paid: interest in a close company: ‘eligibility requirements’
  • SAIM10230 · Relief for interest paid: interest in a close company: the ‘full-time working conditions’
  • SAIM10240 · Relief for interest paid: interest in a close company: ‘material interest conditions’
  • SAIM10250 · Relief for interest paid: interest in a close company: recovery of capital
  • SAIM10260 · Relief for interest paid: interest in a close company: ‘capital recovery condition’: example
  • SAIM10270 · Relief for interest paid: interest in an employee-controlled company
  • SAIM10280 · Relief for interest paid: interest in a partnership: introduction
  • SAIM10290 · Relief for interest paid: interest in a partnership: ‘eligibility requirements’
  • SAIM10300 · Relief for interest paid: interest in a partnership: film partnerships
  • SAIM10310 · Relief for interest paid: interest in a partnership: recovery of capital
  • SAIM10320 · Relief for interest paid: interest in a partnership: return of partnership capital
  • SAIM10330 · Relief for interest paid: interest in a co-operative
  • SAIM10340 · Relief for interest paid: continuity of relief on business successions
  • SAIM10350 · Relief for interest paid: loan to pay inheritance tax
  1. Relief for interest paid: overview and contents
  2. Relief for interest paid: reasonable commercial rate

SAIM10090 | Relief for interest paid: reasonable commercial rate

From HM Revenue & Customs · Savings and Investment Manual

Reasonable commercial rate

When assessing whether the interest paid to date is in excess of a reasonable commercial rate the judgement should be made on the basis that this would be the expected rate on a loan on the same terms as the taxpayer’s loan taken out at the same time.

For example, if the taxpayer took out a loan for 5 years at a fixed rate of 7% (a reasonable commercial rate at that time) but by the end of year 5 the lender’s standard variable mortgage rate was only 4% you should not argue that the 7% paid in year 5 was in excess of a reasonable commercial amount. This is because the rate was a reasonable commercial rate for a 5-year fixed-rate deal taken out 5 years previously.

Whether interest is paid at a ‘reasonable commercial rate’ will depend on the perceived risk to the lender. A borrower with a poor credit history, or someone taking out an unsecured personal loan, is likely to have to pay a higher rate of interest than the standard variable mortgage rate.

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