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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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PRT: associated party transactions - interest and other pecuniary obligations

Interest or any other form of pecuniary obligation incurred in obtaining a loan or any other form of credit is specifically excluded as disallowable when considering the cost to the affiliate of providing the asset or services in question (OTA75\Sch4\Para(2)(1B)). In effect the prohibition in OTA75\S3(4)(a) is applied - (see OT09475).