Commentary on Sections Overview Overview Section 441: Loan relationships for unallowable purposes
1275.This section prevents a company from bringing into account debits in respect of a loan relationship with an “unallowable purpose” (defined in the following section) or exchange gains on such a loan relationship. It is based on paragraph 13(1) and (1A) of Schedule 9 to FA 1996. Once such debits or credits are disallowed they are not brought into account for any other tax purposes.