Commentary on Sections Overview Overview Section 447: Exchange gains and losses on debtor relationships: loans disregarded under Schedule 28AA to ICTA
1290.This and the following four sections provide rules for exchange gains and losses on loan relationships which are not on arm’s length terms. It is based on paragraph 11A(1) to (3) of Schedule 9 to FA 1996 and paragraph 8(1) and (3) of Schedule 28AA to ICTA.
1291.The section leaves exchange gains and losses, or a proportion of them, out of account where, under Schedule 28AA to ICTA, the whole or part of a loan representing a debtor relationship is ignored.