Finance Act 2000

Foreign tax on amounts underlying non-trading credits

24 (1) Amend section 807A of the Taxes Act 1988 (disposals and acquisitions of company loan relationships) as follows.

(2) In subsection (2) (tax which is to be treated as if it were to be disregarded for certain purposes) in paragraph (b), after “is attributable, on a just and reasonable apportionment,” insert “(i)” and at the end insert “; or

(ii) to so much of a relevant qualifying payment as, on such an apportionment, is attributable to a time when the company is not a party to the interest rate or currency contract concerned”.

(3) In subsection (7), insert the following definition at the appropriate place—

““relevant qualifying payment” means a qualifying payment, for the purposes of Chapter II of Part IV of the [1994 c. 9.] Finance Act 1994, falling within section 153(1)(a) or (b) of that Act;”.

(4) This paragraph has effect in relation to accounting periods ending on or after 21st March 2000.