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HMRC internal manual

Corporate Finance Manual

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HM Revenue & Customs
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Deemed loan relationships: disguised interest: excluded shares: basic rules

Excluded shares: the basic rules

CTA09/486E(1) sets out the basic rule that the disguised interest rules will not apply in any ‘relevant accounting period’ where the return ‘involves only’ ‘relevant shares’.

Relevant accounting period

CTA09/486E(2) defines ‘relevant accounting period’ as:

  • beginning when the holding company becomes party to the arrangement or, if later, when the arrangement begins to produce a return to the company;
  • ending when the holding company ceases to be party to the arrangement or, if earlier, the end of the relevant accounting period.

See CFM42160 for more in the meaning of ‘involves only’, and CFM42170 for more on ‘relevant shares’.