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HMRC internal manual

Corporate Finance Manual

Old rules: loan relationships: quick guide to converting from FA 1996 to CTA 2009

Converting from FA 1996 to CTA 2009

The table below provides a guide to certain key terms used in the guidance on the loan relationships legislation at CFM80100 onwards. These key terms are explained more fully in the guidance on the current rules.

Subject FA96 CTA 2009 Reference
Profits from loan relationships chargeable as income under this Chapter/Part 80(1) 295(1), S299(1) CFM30170
Priority of loan relationship rules for corporation tax purposes 80(5) 464(1), (2) CFM30130
Loan relationship - a money debt arising from a transaction for the lending of money 81(1) 302(1) CFM31010
Money debt includes an instrument issued 81(3) 303(3) CFM30140
Trading credits and debits brought into account as trade receipts 82(2) 297(2), (3) CFM30180
Non-trading credits and debits 82 301 CFM32030
Profits includes profits from related transactions and capital profits 84(1) 293(1), (3) CFM30170
Fairly represents 84 (1) 307(3) CFM33020
Pre-loan relationship and abortive expenses 84(4) 329(1), (2) CFM33060
Meaning of ‘related transaction’ 84(5), (6) 304(1), (2) CFM31120
Exchange gains and losses included 84A 328 CFM33010
Computation in accordance with GAAP 85A 307(2), 313(1), 309 CFM33070
  Amounts recognised in determining company’s profit or loss include amounts in P&L etc 85B 308 CFM33100
  Derecognition 85C 311, 312 CFM33120
  Connection 87 348-351, 466, 467 CFM35170
  Control 87A 472 CFM35120
  Shares as debt 91A-91G PT6/CH7 CFM45000
  Connected parties late interest PARA 2 PT5/CH8 CFM35800
  Deemed debt releases on connected company impaired debts PARA4A 361 - 363 CFM35430
  Releases of debt and insolvency PARA 5 322, 323, 358, 359 CFM33190
  Impaired or released consortium debt PARA5ZA, PARA5A PT5/CH7 CFM35600
  Connected parties impairment losses PARA6    


PARA6C 323, 352, 354, 355, 357, 360 CFM35310    
  No debits from revaluation PARA6D 324, 325 CFM33210