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but relief, for interest paid by the investing company, which has been allowed by virtue of this paragraph shall be deemed for the purposes mentioned in Paragraph 4(5) of Schedule 24to the Principal Act to have been allocated by the company concerned to the relevant income of the company by reference to which the relief for the interest was allowed, and the foreign tax in respect of that relevant income shall be disregarded for the purposes of paragraph 9E and 9F of Schedule 24.

but relief, for interest paid by the investing company, which has been allowed by virtue of this paragraph shall be deemed for the purposes mentioned in Paragraph 4(5) of Schedule 24to the Principal Act to have been allocated by the company concerned to the relevant income of the company by reference to which the relief for the interest was allowed, and the foreign tax in respect of that relevant income shall be disregarded for the purposes of paragraph 9E and 9F of Schedule 24.

(b) For the purposes of this section and sections 248 and 249, a company shall be regarded as connected with another company if it would be so regarded for the purposes of the Tax Acts by virtue of section 10 and , except for the purposes of subsection (4A) subsections (4A) and (4E), if it is a company referred to in subsection (2)(a).

(5) Interest eligible for relief under this section shall be deducted from or set off against the income (not being income referred to in subsection (2)(a) of section 25) of the borrower for the year of assessment in which the interest is paid and tax shall be discharged or repaid accordingly.

(i) by virtue of a change in a rate of exchange (within the meaning of section 79), or

(ii) from any contract entered into by the company for the purpose of eliminating or reducing the risk of loss being incurred by the company due to a change in a rate of exchange (within the meaning of section 79) or in a rate of interest.

“trading stock” has the same meaning as in section 89.

and such other company (in this subsection and subsection (4D) referred to as the “other company”) uses those subscriptions or moneys to provide specified intangible assets (within the meaning of section 291A) in respect of which allowances are to be made to it under section 284 as applied by section 291A, then, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of so much (in this subsection and subsections (4C) and (4D) referred to as the “relevant interest”) of the interest paid in an accounting period by the investing company on the loan, or the part of the loan, as the case may be, as exceeds the sum of—

(c) (i) Where, in an accounting period, interest is paid by an investing company on a loan to defray money applied in lending to another company (in this paragraph referred to as the “other company”) money which is used wholly and exclusively for the purposes of acquiring a trade (in this subsection referred to as an “acquired trade”) which immediately before its acquisition by the other company was carried on by a company which was not within the charge to corporation tax, then paragraph (b) shall not apply to that loan and, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of the interest paid in an accounting period by the investing company on the loan shall not exceed the amount of the profits or gains of the other company in respect of the acquired trade for the corresponding period.

(d) (i) Where, in an accounting period, interest is paid by an investing company on a loan to defray money applied in lending to another company (in this paragraph referred to as the “other company”) money which is used wholly and exclusively for the purposes of acquiring an asset (in this paragraph referred to as an “acquired asset”) which is leased by the other company for that accounting period in the course of a trade (in this paragraph referred to as the “first-mentioned trade”) then, if immediately before that asset was acquired by the other company it was not in use for the purposes of a trade carried on by a company which was within the charge to corporation tax, paragraph (b) shall not apply to that loan and, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of the interest paid in the accounting period by the investing company on the loan shall not exceed the amount of the profits or gains of the first-mentioned trade for the corresponding period as is attributable to the acquired asset.

(b) Where a loan to an investing company, to which subsection (2) applies, has been applied in lending to another company (in this paragraph referred to as the “other company”) not within the charge to corporation tax money which is used wholly and exclusively for the purposes of the trade or business of the other company then, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of so much of the interest paid (referred to in this paragraph as the “interest paid”) in an accounting period by the investing company on the loan, as exceeds the amount (including a nil amount) of any interest, arising to the investing company on the money lent to the other company, for the relevant period, shall not exceed the amount by which the interest paid exceeds the interest (if any) arising to the other company in that relevant period in respect of the money so used.

(c) Where a loan to an investing company, to which subsection (2) applies, has been applied in lending to another company (in this paragraph referred to as the “other company”) money which is used wholly and exclusively for the purposes of the trade or business of a connected company not within the charge to corporation tax then, notwithstanding subsection (3) and section 243—

(4G) Where a loan to an investing company, to which subsection (2) applies, has been applied in lending to a company money which is used wholly and exclusively for the purposes of the trade of the company or of a connected company, the interest on the loan shall be treated for the purposes of Chapter 5 of Part 12 as relevant trading charges on income within the meaning of section 243A.

(1) (a) In this section and in sections 248 and 249—

(b) For the purposes of this section and sections 248 and 249, a company shall be regarded as connected with another company if it would be so regarded for the purposes of the Tax Acts by virtue of section 10 and , except for the purposes of subsection (4A) subsections (4A) and (4E), if it is a company referred to in subsection (2)(a).

(1) (a) In this section and in sections 248 and 249—

(b) For the purposes of this section and sections 248 and 249, a company shall be regarded as connected with another company if it would be so regarded for the purposes of the Tax Acts by virtue of section 10 and , except for the purposes of subsection (4A) subsections (4A) and (4E), if it is a company referred to in subsection (2)(a).

(2) This section shall apply to a loan to a company (in this section and in section 249(1) referred to as “the investing company”) to defray money applied—

(c) the investing company shows that in the period referred to in paragraph (b) it has not recovered any capital from the company or from a connected company apart from any amount taken into account under section 249.

and such other company (in this subsection and subsection (4D) referred to as the “other company”) uses those subscriptions or moneys to provide specified intangible assets (within the meaning of section 291A) in respect of which allowances are to be made to it under section 284 as applied by section 291A, then, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of so much (in this subsection and subsections (4C) and (4D) referred to as the “relevant interest”) of the interest paid in an accounting period by the investing company on the loan, or the part of the loan, as the case may be, as exceeds the sum of—

(A) if that relevant interest had been incurred by the other company in connection with the provision of a specified intangible asset by reference to which allowances were to be made to it under section 284 as applied by section 291A in addition to any other interest so incurred by it, and

and such other company (in this subsection and subsection (4D) referred to as the “other company”) uses those subscriptions or moneys to provide specified intangible assets (within the meaning of section 291A) in respect of which allowances are to be made to it under section 284 as applied by section 291A, then, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of so much (in this subsection and subsections (4C) and (4D) referred to as the “relevant interest”) of the interest paid in an accounting period by the investing company on the loan, or the part of the loan, as the case may be, as exceeds the sum of—

and such other company (in this subsection and subsection (4D) referred to as the “other company”) uses those subscriptions or moneys to provide specified intangible assets (within the meaning of section 291A) in respect of which allowances are to be made to it under section 284 as applied by section 291A, then, notwithstanding subsection (3) and section 243, the amount of the relief to be given in respect of so much (in this subsection and subsections (4C) and (4D) referred to as the “relevant interest”) of the interest paid in an accounting period by the investing company on the loan, or the part of the loan, as the case may be, as exceeds the sum of—

(A) if that relevant interest had been incurred by the other company in connection with the provision of a specified intangible asset by reference to which allowances were to be made to it under section 284 as applied by section 291A in addition to any other interest so incurred by it, and

(B) notwithstanding subsection (6) of section 291A, if any additional restrictions of deductions, whether for allowances or interest, which would then be required by that subsection, were to be made solely by restriction of the deduction for that relevant interest,

(ii) an asset referred to in subsection (4B) which is treated by the provisions of section 291A(2) as plant and machinery for the purposes of Chapters 2 and 4 of Part 9, or

(A) amounts of any relief, which is referable to the second-mentioned period, surrendered at any time by the electing company under Chapter 5 of Part 12, or

(B) amounts, which are not amounts referred to in clause (A), of any losses which could have been set off under section 396(2) against profits of the second-mentioned period but which were not set off against those profits,

(A) amounts of any relief, which is referable to the second-mentioned period, surrendered at any time by the electing company under Chapter 5 of Part 12, or

“control” shall be construed in accordance with section 432;