Interest and currency management - debt instruments

Authoritative and in-depth analysis of the UK Finance Act 1996 loan relationship legislation addressing the UK tax considerations that arise in the context of treasury management for accounting periods beginning on or after 1 October 2002 as regards debt funding and debt investment. Special focus is given to the cases where the tax treatment of a loan relationship might differ from its accounting treatment and to the cases where a borrower may be denied tax relief for interest payable on a loan or loan note and where a borrower might be degrouped for tax purposes. The withholding tax position and the ways in which a lender can pay annual interest gross are considered.