Part 5Loan Relationships
Chapter 15Tax avoidance
Transactions not at arm's length: general
446Bringing into account adjustments made under F1Part 4 of TIOPA 2010
(1)
This section deals with the credits and debits which are to be brought into account for the purposes of this Part as a result of F2Part 4 of TIOPA 2010 (provision not at arm's length) applying in relation to a company's loan relationships or related transactions.
(2)
Subsection (3) applies if under F3Part 4 of TIOPA 2010 an amount (“the imputed amount”) is treated as an amount of profits or losses arising to a company from any of its loan relationships or related transactions.
(3)
Credits or debits relating to the imputed amount are to be brought into account for the purposes of this Part to the same extent as they would be in the case of an actual amount of such profits or losses.
(4)
Subsection (5) applies if under F4Part 4 of TIOPA 2010 an amount is treated as interest payable under any of a company's loan relationships.
(5)
Credits or debits relating to that amount are to be brought into account for the purposes of this Part to the same extent as they would be in the case of an actual amount of such interest.
(6)
Subsection (7) applies if under F5Part 4 of TIOPA 2010 an amount is treated as expenses incurred by a company under or for the purposes of any of its loan relationships or related transactions.
(7)
Debits relating to the amount are to be brought into account for the purposes of this Part to the same extent as they would be in the case of an actual amount of such expenses.