INTM501060 - Interest imputation: transfer pricing the lender: treatment of exchange differences
The rules covered by this guidance page were subject to reform in Finance Bill 2025- 26. As such you may need to consider the draft guidance at INTM 414000 from 1 January 2026.
Where transfer-pricing rules operate to impute interest (or a higher rate of interest) on the whole of an outward loan, all the exchange rate gains and losses continue to be recognised in full. However, because of CTA09/S447-S452 (previously FA96/SCH9/PARA11A), exchange gains or losses on creditor loan relationships are to be disregarded only where, and to the extent that, the loan fulfils an equity function.
For further information see CFM38100.