So this new measure restricts the deduction for interest, etc., for anyone subject to Income Tax. (New ITTOIA 272A)
Companies are explicitly saved.
Separate measures allow an individual BR tax relief where he or she has an interest in (up to) 100% of profits including residential property business income. This will apply to individuals, (including joint investors and) partnerships (s274A)
Separate measures afford individuals tax relief where they take out a loan to invest in a partnership which lets out residential property. (ITA 07 s399A)
Anyone see anything for Trusts? Because I didn't. I suppose that where an individual has an IIP then he or she will fall within the scope of s274A. But discretionary trusts look to me like they've been either overlooked or deliberately broadsided.
Agree / disagree?
Regards,
Lambs
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