C1C2C3C4Part 4Transfer pricing

Annotations:
Modifications etc. (not altering text)
C1

Pt. 4 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)

C4

Pt. 4 excluded (with effect in accordance with s. 148 of the amending Act) by Finance Act 2012 (c. 14), s. 129(11) (with s. 147, Sch. 17)

C4C5CHAPTER 4Position, if only one affected person potentially advantaged, of other affected person

Annotations:
Modifications etc. (not altering text)
C5

Pt. 4 Chs. 1 and 3-6 applied (1.4.2022 in relation to accounting periods beginning on or after that date) by Finance Act 2022 (c. 3), s. 51(1), Sch. 9 paras. 3, 4

F1Treatment of interest where claim prevented by section 174A

Annotations:
Amendments (Textual)
F1

S. 187A and cross-heading inserted (with effect in accordance with s. 75(5)(6) of the amending Act) by Finance Act 2014 (c. 26), s. 75(4)

187AExcess interest treated as a F2... distribution

1

Subsection (2) applies if Conditions A to C in section 187 are met in circumstances where section 174A prevents a claim under section 174.

2

The interest paid under the actual provision, so far as it exceeds ALINT, is treated for the purposes of the Income Tax Acts as a dividend paid by the company which paid the interest (and, accordingly, as a F3...distribution).