Part 11Manufactured payments and repos
Chapter 2Manufactured payments
Manufactured interest on UK securities
579Allowable deductionsF1...
1
This section applies to a person who pays manufactured interest as mentioned in section 578(1).
2
The gross amount of the manufactured interest is allowable for income tax purposes as a deduction in calculating the net income of the payer (see Step 2 of the calculation in section 23).
This is subject to subsection (3).
F23
It is—
a
deductible by virtue of subsection (2) only so far as it is not otherwise deductible, and
b
not deductible (whether by virtue of subsection (2) or otherwise) if it (or any part of it) is made directly or indirectly in consequence of, or otherwise in connection with, avoidance arrangements.
9
For the purposes of subsection (3)(a) an amount is F3otherwise deductible if, apart from this section, it is—
a
deductible in calculating any of the payer's profits or gains for income tax purposes, or
b
deductible for those purposes in calculating the net income of the payer.
F410
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