My client (A) has a UK trading company (B) with lots of surplus cash. (A) also has a non resident reading company (C) in Denmark.
(A) would like the the UK company(B) to loan money to non resident company(C) at a commercial rate of interest.
The Danish company is involved with forestry in Denmark and would use the cash for the purposes of its trade.
Could S455 CTA 2010 (S419 ICTA 1988) be applied because of this loan?
Ian Wright
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