Commentary on Sections Overview Overview Section 449: Exchange gains and losses on creditor relationships: no corresponding debtor relationship
1293.This section applies where a company is in a creditor relationship and the transaction giving rise to the loan would not have been made on arm’s length terms. It is based on paragraph 11A(4) and (5) of Schedule 9 to FA 1996. The section leaves exchange gains and losses out of account where there is no corresponding debtor relationship (explained in section 450).