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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Other tax rules on corporate finance: overview

Tax rules on corporate debt outside Parts 5 to 7 of the Corporation Tax Act 2009

Most of the tax rules relating to corporate finance are to be found in the legislation in Parts 5 to 7 of CTA 2009 which deal with loan relationships and derivative contracts. However, there are a number of rules relating to the taxation of corporate debt which are to be found outside the main body of the loan relationships and derivative contracts legislation.

The rules are those found in

  • other parts of CTA09
  • other primary tax legislation
  • secondary legislation (Regulations and Orders) made under powers in Parts 5 to 7 CTA09.

CFM70020 summarises these other rules and explains how the guidance is set out.