Are you a control freak?

MARTIN MANN looks at changes in control tests and the effect these may have in common scenarios involving interest and a write off of debts between connected companies.

THE TAXES ACTS are peppered with a bewildering array of definitions of control. When loan relationships were introduced in 1996 the definition of parties with a connection contained a familiar concept of control. However if like me you are mystified when you look at loan relationships read further. Within the provisions special rules apply for companies under common control but not as you know it.
The existing régime covering loan relationships is set out in the Finance Act 1996. A significant part of the loan relationship rules relate to connected parties and the effect such connections have on the late payment of interest and impairment losses (a term introduced to reflect international...