Explanatory Notes

Taxation (International and Other Provisions) Act 2010

2010 CHAPTER 8

18 March 2010

Commentary on Sections

Part 7: Tax treatment of financing costs and income

Chapter 7: “Financing expense amount” and “financing income amount”
Section 322: Stranded deficits in non-trading loan relationships: financing expense

606.This section deals with stranded deficits in non-trading loan relationships from the perspective of the company incurring the financing expense and prevents a financing expense which meets condition A in section 313 from being treated as such. It is based on paragraph 63 of Schedule 15 to FA 2009.