Other tax rules on corporate finance: stock loans: taxation
Stock loan tax issues
Stock lending gives rise to a number of tax problems.
The disposals and acquisitions would, in the case of an asset representing a loan relationship, constitute loan relationship related transactions. CTA09/S332 provides that where a company ceases to be party to a loan relationship but in accordance with GAAP continues to recognise amounts in respect of that relationship in determining its profit or loss, these amounts are brought into account in accordance with the loan relationships rules. See CFM33290.
See CFM74160 - CFM74180 for details of anti-avoidance measures.