Part 8Other reliefs

Chapter 1Interest payments

The relief: introduction

387Exclusion of double relief etc

1

Interest for which relief is given under this Chapter is not allowable as a deduction for any other income tax purposes.

2

No relief is given under this Chapter for any tax year for the payment of any interest taken into account in calculating the profits of—

a

any trade, profession or vocation,

b

any UK property business, or

c

any overseas property business.

3

If interest is so taken into account, no relief is given under this Chapter for any relevant tax year for other interest on the same debt or liability.

4

A tax year is a relevant one if the interest has been taken into account in calculating the profits of the trade, profession, vocation or business of the tax year.

5

For the purposes of subsection (3) all interest which—

a

is capable of being taken into account in calculating the profits of a trade, profession, vocation or business, and

b

is payable by the same person on money advanced to the person on current account,

is treated as interest on the same debt.

6

It does not matter whether the money is advanced—

a

on one or more accounts, or

b

by the same or separate banks or other persons.

7

The reference in subsections (2) to (4) to interest taken into account is a reference to interest allowed as a deduction in an assessment which can no longer be varied (whether on appeal or otherwise).