Commentary on Sections Overview Overview Section 404: Eligibility requirements for interest on loans within section 403
1136.This section provides that interest on loans to pay inheritance tax is eligible for relief only if it is paid in respect of a period ending within 12 months of the loan being made. It is based on section 364(1) and (4) of ICTA.
1137.Section 364(4)(b) of ICTA states that “references to interest in respect of a period ending with a given time apply whether or not interest continues to run after that time”. This has been rewritten by using the words “so far as”.
1138.Section 368(2) of ICTA is redundant and has not been rewritten. See Change 73 in Annex 1.