Section 387 — Income Tax Act 2007: Exclusion of double relief etc

Exclusion of double relief etc 387 1 Interest for which relief is given under this Chapter is not allowable as a deduction for any other income tax purposes.

2 No relief is given under this Chapter for any tax year for the payment of any interest taken into account in calculating the profits of—

a any trade, profession or vocation, b any UK property business, or c any overseas property business.

3 If interest is so taken into account, no relief is given under this Chapter for any relevant tax year for other interest on the same debt or liability.

4 A tax year is a relevant one if the interest has been taken into account in calculating the profits of the trade, profession, vocation or business of the tax year.

5 For the purposes of subsection (3) all interest which—

a is capable of being taken into account in calculating the profits of a trade, profession, vocation or business, and b is payable by the same person on money advanced to the person on current account, is treated as interest on the same debt.

6 It does not matter whether the money is advanced—

a on one or more accounts, or b by the same or separate banks or other persons.

7 The reference in subsections (2) to (4) to interest taken into account is a reference to interest allowed as a deduction in an assessment which can no longer be varied (whether on appeal or otherwise).