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Tax Avoidance › Loan Documentation › HMRC

Cadwalader, Wickersham & Taft LLP

Ascertaining the Purpose of a Loan Relationship

Cadwalader, Wickersham & Taft LLP on

The UK has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationship Regime”). The Loan Relationship Regime contains wide-ranging anti-avoidance...more

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