The Double Taxation Relief (Taxes on Income) (Foreign Loan Interest) Regulations 1988

Determination of interbank bid rates of interest

4.—(1) Where the interbank bid rates referred to in regulation 3(3) are to be taken into account in determining such a just and reasonable attribution as is referred to in subsection (5B), those bid rates shall be taken to be the average of the bids that would be made in relation to each interest period applicable to the loan in the relevant interbank market on terms corresponding to the terms of the loan.

(2) In this regulation “interbank market” means the market that exists between banks in a particular place for the purpose of borrowing and lending funds and dealing in currencies; and “the relevant interbank market” means the interbank market which is most appropriate in relation to a loan having regard to all the terms on which it was made.