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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Loan relationships: a short guide: who is taxable?

Who is taxable?

A company is taxable on the ‘credits’ and ‘debits’ that arise on its ‘creditor loan relationships’ and its ‘debtor loan relationships’.

A company that lends money or holds a security has a ‘creditor relationship’.

A company that borrows money or issues a security has a ‘debtor relationship’.

CFM30170 has more on the terms ‘credits’ and ‘debits’. Note that these words refer respectively to receipts and expenses. They are not used as they are in accountancy to mean also liabilities and assets.