{
  "url": "https://openlegislation.uk/corporation-tax-act-2010/section-18I",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2010/section-18I.json",
  "legislation": "ukpga/2010/4",
  "legislation_title": "Corporation Tax Act 2010",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2010",
  "path": "section/18I",
  "kind": "section",
  "number": "18I",
  "heading": "Association through a loan creditor",
  "text": "(1) A company (“A”) is not under the control of another company (“B”) for the purposes of section 18E(4) if—\n(a) B is a loan creditor of A,\n(b) there is no other connection between A and B, and\n(c) either—\n(i) B is not a close company, or\n(ii) B's relationship to A as a loan creditor arose in the ordinary course of a business which B carries on.\n(2) Subsection (3) applies if—\n(a) two companies (“A” and “B”) are controlled by the same person who is a loan creditor of each of them,\n(b) there is no other connection between A and B, and\n(c) either—\n(i) the loan creditor is a company which is not a close company, or\n(ii) the loan creditor's relationship to each of A and B as a loan creditor arose in the ordinary course of a business which the loan creditor carries on.\n(3) In determining for the purposes of this Part whether A and B are associated with each other, rights which the loan creditor has as a loan creditor of A, or as a loan creditor of B, are ignored.\n(4) In subsection (2)(a) “control” has the same meaning as in section 18E(4).\n(5) In this section—\n(a) “connection” includes a connection in the past as well as a connection in the present, and\n(b) references to a connection between two companies include any dealings between them.\n(6) In this section references to a loan creditor of a company are to be read in accordance with section 453.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 3A inserted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 3"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/4/section/18I",
    "retrieved_at": "2026-10-29T09:10:29.433154+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."
}