OT22040 - Interest and Financing

Section 787 ICTA 1988 and Para 13(4) Sch 9 FA 1996 anti avoidance provisions

Where borrowing is considered to be on non-commercial terms the anti-avoidance provisions of ICTA 88/s787 and FA96/Sch9/Para 13(4) may need to be considered. The Assistant Director should be consulted at an early stage, prior to a final view being reached on whether the anti- avoidance provisions should be applied in any particular case.