CTM34730 - Residence: dual resident companies: early payment of charges on income

ICTA88/SCH17/PARA6 applies to the usual dual resident investing company whose interest payments are treated as charges on income. It deals with the situation where either interest has been paid before the due date or where arrangements have been made on or after 5 December 1986 (the date the proposed legislation was announced) to alter the due date.

But it only applies if it appears to the Board that the sole or main benefit accruing from the early payment, or from the arrangements to alter the due date, would be to attribute the interest payment for tax purposes to an accounting period which ended before 1 April 1987 and thus provide the dual resident investing company with a loss, or increase an existing loss, which would still be available for set-off by way of group relief.