Skip to content
Solved
SearchBrowse
Sign in

Contents

Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading When foreign tax disregarded in applying Part for corporation tax purposes

  • Section 107 Disregard of foreign tax referable to derivative contract
  • Section 108 Disregard of foreign tax attributable to interest under a loan relationship
  • Section 109 Repo cases in which no disregard under section 108
  • Section 110 Stock-lending cases in which no disregard under section 108
  1. When foreign tax disregarded in applying Part for corporation tax purposes
  2. Stock-lending cases in which no disregard under section 108

Section 110 | Stock-lending cases in which no disregard under section 108

From legislation.gov.uk

(1)Tax attributable to interest accruing to a company under a loan relationship is within this section if—

(a)at the time when the interest accrues, the company has ceased to be a party to the relationship by reason of having made the initial transfer under or in accordance with any stock lending arrangement relating to that relationship, and

(b)that time is in the period for which the arrangement has effect.

(2)In this section—

“the initial transfer”, in relation to a stock lending arrangement, means the transfer mentioned in section 263B(1)(a) of TCGA 1992, and

“stock lending arrangement” has the meaning given by section 263B of TCGA 1992.

(3)In this section, a reference to the period for which a stock lending arrangement has effect is to the period from the making of the initial transfer until the earlier of—

(a)the time when the transfer mentioned in section 263B(1)(b) of TCGA 1992 takes place, and

(b)the time when it becomes apparent that that transfer will not take place.

PreviousNext
PrivacyTerms