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CTM50310 - Loan relationships: overview: new Case III

The definition of Case III in ICTA88/S18 was amended by FA96/SCH14/PARA5.

There are now two definitions of Case III:

  • one for IT, which is unchanged, and
  • one for CT, which is new.

The new ICTA88/S18 (3A) applies for CT. It charges tax in respect of:

  • profits and gains arising from loan relationships, and
  • any annuity or other annual payment which is payable in respect of anything other than a loan relationship, and
  • any discount arising otherwise than in respect of a loan relationship, see CTM50320.