{
  "url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-A1/paragraph-5",
  "json_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-A1/paragraph-5.json",
  "legislation": "ukpga/1988/1",
  "legislation_title": "Income and Corporation Taxes Act 1988",
  "legislation_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988",
  "path": "schedule/A1/paragraph/5",
  "kind": "paragraph",
  "number": "5",
  "heading": null,
  "text": "(1) No deduction is allowed in respect of payments of interest or other financing costs by the permanent establishment to any other part of the non-resident company, except as provided by sub-paragraph (2).\n(2) The restriction in sub-paragraph (1) above does not apply to interest or other costs of financing that are payable in respect of borrowing by the permanent establishment in the ordinary course of a financial business carried on by it.\n(3) In sub-paragraph (2) “financial business” means any of the following—\n(a) banking, deposit-taking, money-lending or debt-factoring, or a business similar to any of those;\n(b) dealing in commodity or financial futures.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1988/1/schedule/A1/paragraph/5",
    "retrieved_at": "2026-10-29T09:49:54.309394+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."
}