{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-302",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-302.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/302",
  "kind": "section",
  "number": "302",
  "heading": "“Loan relationship”, “creditor relationship”, “debtor relationship”",
  "text": "(1) For the purposes of the Corporation Tax Acts a company has a loan relationship if—\n(a) the company stands in the position of a creditor or debtor as respects any money debt (whether by reference to a security or otherwise), and\n(b) the debt arises from a transaction for the lending of money.\n(2) References to a loan relationship and to a company being a party to a loan relationship are to be read accordingly.\n(3) For cases where this Part applies as if a relationship were a loan relationship despite the money debt not arising from a transaction for the lending of money see Chapter 2 of Part 6 (relevant non-lending relationships).\n(4) See also the following provisions of Part 6 (under which other matters are treated as loan relationships or rights, payments or profits under loan relationships)—\n(a) Chapter 3 (OEICs, unit trusts and offshore funds),\n(b) Chapter 4 (building societies),\n(c) Chapter 5 (registered societies),\n(d) Chapter 6 (alternative finance arrangements),\n(e) Chapter 7 (shares with guaranteed returns etc),\n(f) Chapter 8 (returns from partnerships),\n(g) Chapter 9 (manufactured interest etc),\n(h) Chapter 10 (repos), and\n(i) Chapter 11 (investment life insurance contracts).\n(5) In this Part “creditor relationship”, in relation to a company, means any loan relationship of the company where it stands in the position of a creditor as respects the debt in question.\n(6) In this Part “debtor relationship”, in relation to a company, means any loan relationship of the company where it stands in the position of a debtor as respects the debt in question.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in Act substituted (1.8.2014) by Co-operative and Community Benefit Societies Act 2014 (c. 14), s. 154, Sch. 4 para. 143 (with Sch. 5)"
    },
    {
      "type": "C",
      "label": "C1",
      "text": "S. 302(1) applied (19.7.2011) by Finance Act 2011 (c. 11), Sch. 19 para. 26(7)"
    },
    {
      "type": "C",
      "label": "C2",
      "text": "S. 302(1) applied by 2011 c. 11, Sch. 19 para. 15Z2(7) (as inserted (with effect in accordance with Sch. 9 para. 35 of the amending Act) by Finance Act 2018 (c. 3), Sch. 9 para. 2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/4/section/302",
    "retrieved_at": "2026-10-29T09:11:19.560467+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}