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HMRC internal manual

Company Taxation Manual

Building societies: application of CT: permanent interest bearing shares (PIBS): incidental costs

Societies issuing PIBS are allowed relief under CTA2009/S131 (formerly ICTA88/S477B) for the incidental costs of obtaining this finance, provided that the interest payable on the shares is itself deductible and to the extent that such costs are not brought into account as debits under CTA2009/Chapter 6A Part 6 (formerly FA 1996/Chapter 2 Part 4). The ‘incidental costs of obtaining finance’ means expenditure on fees, commissions, advertising, printing and other incidental matters (but excluding stamp duty) which is expenditure wholly and exclusively incurred for the purposes of obtaining the finance (whether or not it is obtained), or of providing security for it or of repaying it.