Commentary on Sections Overview Overview Section 451: Exception to section 449 where loan exceeds arm’s length amount
1296.Where a loan would, on arm’s length terms, have been of an amount more than nil but less than the full amount this section takes into account a suitable proportion of the exchange gains and losses for the purposes of this Part. It is based on paragraph 11A(5) and (6) of Schedule 9 to FA 1996.