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HMRC internal manual

Business Income Manual

Specific deductions - interest: Exclusion of double relief

This chapter applies for Income Tax purposes to the computation of trade profits and property income. References in the text to a ‘business’ should therefore be taken to include both trades and property businesses. The chapter does not apply for Corporation Tax purposes, where there are separate rules in the loan relationships legislation (see CFM11000).

S52 Income Tax (Trading and Other Income) Act 2005

Interest which may be deductible in the calculation of business profits may also qualify for relief under the provisions of S383-S412 Income Tax Act 2007 (see SAIM11000 onwards). No deduction in computing business profits can be made for any interest in respect of which relief is given under those provisions.