Corporation Tax Act 2009 section 304

"Related transaction"

Section 304 defines what a "related transaction" means in relation to a loan relationship for the purposes of the loan relationships rules.

• A related transaction is any disposal or acquisition — whether whole or partial — of rights or liabilities under a loan relationship.
• This includes transfers or extinguishments through sale, gift, exchange, surrender, redemption, or release.
• The definition is deliberately broad, capturing any event that moves or eliminates rights or obligations connected to a loan relationship.
• The concept of a related transaction is important because specific tax rules govern how credits and debits arising from such transactions are recognised and calculated.