Textual Amendments
F1S. 27 cross-heading inserted (6.4.2024 for the tax year 2024-25 and subsequent tax years) by Finance Act 2024 (c. 3), Sch. 10 paras. 12, 47 (with Sch. 10 paras. 48-50)
(1)In the Income Tax Acts, in the context of the calculation of the profits of a trade, references to receipts and expenses are to any items brought into account as credits or debits in calculating the profits.
(2)There is no implication that an amount has been actually received or paid.
(3)This section is subject to any express provision to the contrary.
The rules for calculating the profits of a trade need to be read with—
(a)the provisions of CAA 2001 which treat charges as receipts of a trade, and
(b)the provisions of CAA 2001 which treat allowances as expenses of a trade.
(1)Subsection (2) applies—
(a)for the purpose of bringing into account an amount arising in respect of a transaction involving money's worth entered into in the course of a trade, and
(b)if an amount at least equal to the amount that would be brought into account under that subsection is not otherwise brought into account as a receipt in calculating the profits of a trade under a provision of this Part other than a provision mentioned in subsection (3).
(2)For the purpose of calculating the profits of the trade, an amount equal to the value of the money's worth is brought into account as a receipt if, had the transaction involved money, an amount would have been brought into account as a receipt in respect of it.
(3)But where another provision of this Part makes express provision for the bringing into account of an amount in respect of money's worth as a receipt in calculating the profits of a trade (however expressed), that other provision applies instead of subsection (2).]
Textual Amendments
F2S. 28A inserted (with effect in accordance with s. 71(7) of the amending Act) by Finance Act 2016 (c. 24), s. 71(2)
For the purpose of calculating the profits of a trade, interest is an item of a revenue nature, whatever the nature of the loan.