BIM45800 - Specific deductions - incidental costs of loan finance: Contents

Introduction and layout of guidance

ITTOIA/S58 and S59 provide a statutory income tax relief for expenditure (the incidental costs of raising loan finance) that would otherwise not be an allowable deduction. The rules were previously in ICTA88/S77.

The rules apply only to income tax. For periods ending up to 31 March 1996 they also applied to CT but that aspect was repealed when the loan relationships rules were introduced. For subsequent periods similar relief is provided under the loan relationships rules. For details see the Corporate Finance Manual. For pre-FA02 legislation, HMRC officers may obtain guidance in the form of archived CTM paragraphs from CT&VAT (Technical): see “Technical help” on the left bar.

The guidance covers the following: