Readers' forum: Puzzling

I am struggling to understand the relationship between the rules on loan interest on money loaned to a partnership and the cap on income tax reliefs.

ITA 2007 s 88 and s 94 allow relief for loan interest paid on (a) money advanced to a partnership to use wholly and exclusively in the trade or (b) in relation to plant and machinery used by the partnership to be treated as a trading loss for the purposes of ITA 2007 s 83 (carried-forward losses) or s 89 (terminal losses). How does this interact with the cap on income tax reliefs in ITA 2007 s 24A? There is minimal guidance on this in BIM45770. ITA 2007 s 88 and s 94 are relevant only if the individual’s total income for the tax year is nil or is insufficient to relieve the loan interest fully. The cap on...