Speed Read: FA 2010 Sch 15 has tightened the circumstances in which a company can avoid being taxed under CTA 2009 s 361 on a deemed profit arising from a debtor relationship where a connected company purchases the corresponding creditor relationship from an unconnected third party at a discount. One consequence will be the need for a different approach to purchases of companies where loans made to the target company would otherwise be acquired at a discount.
