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Business tax: Debt buy-backs

Business tax: Debt buy-backs

Draft guidance has been published on the FA 2010 s 44 and Sch 15 amendments to CTA 2009 in relation to releases of debts by connected companies. HMRC requested comments by 28 May. The guidance will be included in the Corporate Finance Manual. FA 2010 amends the rules on loan relationships that apply to impaired debts between connected companies. The amendments announced last October change the conditions under which exemption from a deemed release is available for transactions occurring on or after 14 October 2009 the Finance Bill lobby notes said. 'They also ensure that releases of debt bought back that benefited from the new corporate rescue and debt for debt exemption will result in the discount being taxed on the debtor.'

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