Taxes Consolidation Act 1997 section 248

Relief to individuals on loans applied in acquiring interest in companies

Section 248 provided tax relief for interest paid by an individual on loans used to acquire shares in, or to lend money to, certain qualifying companies, subject to conditions including active involvement in the company's management.

  • Relief applied to interest on loans taken out by an individual to acquire ordinary shares in a trading company (or its holding company), to lend money to such a company, or to replace a previous qualifying loan.
  • To qualify, the individual had to hold a material interest (more than 5% of ordinary share capital) in the company or a connected company, had to have worked for the greater part of their time in the management of the business, and must not have recovered capital from the company.
  • Qualifying interest was treated as a charge on the individual's income for the year in which it was paid, allowing relief by way of deduction from total income.
  • Relief was not available for loans made on or after 7 December 2010; for earlier qualifying loans, relief was phased out at 75% for 2011, 50% for 2012, and 25% for 2013, with no relief from 2014 onwards.

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