CTM34740 - Residence: dual resident companies: early payment of interest

ICTA88/SCH17/PARA5 covers payments of interest which are deductible in computing the amount of a trading loss and excess management expenses either where one or more of these amounts has been paid before the due date or where arrangements have been made on or after 5 December 1986 to alter the due date. Again, this 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 such amounts for tax purposes to an accounting period which ended before the commencement of the legislation and thus enable the dual resident investing company to create a loss, or increase an existing loss, which would still be available for set-off by way of group relief.