Andy Treavett senior associate at Lovells LLP considers how the loan relationships regime can apply when a debt restructuring involves waivers releases and connected debtors and creditors
When economic circumstances become more challenging a company might find itself at the mercy of its creditors and could be forced to restructure its debts. Any restructuring of a UK tax-resident company's debt will require a careful analysis of the loan relationships code in Finance Act 1996 to ensure that no unwelcome tax charges are triggered. This article considers certain provisions of the code which are relevant to (i) the late payment of interest (ii) loan relationships held by companies which are in financial difficulties or insolvent and (iii) the consequences of the debtor and creditor being or becoming connected.
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Andy Treavett senior associate at Lovells LLP considers how the loan relationships regime can apply when a debt restructuring involves waivers releases and connected debtors and creditors
When economic circumstances become more challenging a company might find itself at the mercy of its creditors and could be forced to restructure its debts. Any restructuring of a UK tax-resident company's debt will require a careful analysis of the loan relationships code in Finance Act 1996 to ensure that no unwelcome tax charges are triggered. This article considers certain provisions of the code which are relevant to (i) the late payment of interest (ii) loan relationships held by companies which are in financial difficulties or insolvent and (iii) the consequences of the debtor and creditor being or becoming connected.
Before...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
