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DB 9: Interest incurred on money borrowed to acquire shares in qualifying companies
or “Tax deductions for interest on loans to buy shares in certain companies”

You could also call this:

“Rules for companies that can't claim expenses related to profit-linked loans”

This part of the law talks about what happens when a company gives out a special kind of loan called a profit-related debenture. If you’re a company that does this, you can’t claim certain things as business expenses to lower your taxes. You can’t claim the interest you pay on the debenture, any costs you have because of the debenture, or any money you spend to borrow the money for the debenture. This rule is very strong - it overrides other parts of the law that might usually let you claim these kinds of expenses. It even overrides the general permission that normally allows you to claim business expenses. This rule is part of section FA 2, which talks about how some debentures are treated differently for tax purposes.

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Next up: DB 10B: Interest or expenditure connected to stapled debt security

or “Companies can't claim deductions for costs related to stapled debt securities”

Part D Deductions
Specific rules for expenditure types

DB 10Interest or expenditure connected to profit-related debentures

  1. This section applies for the purposes of section FA 2 (Recharacterisation of certain debentures).

  2. A company issuing a profit-related debenture is denied a deduction for—

  3. interest payable under the debenture; or
    1. expenditure or loss incurred in connection with the debenture; or
      1. expenditure or loss incurred in borrowing the money secured by or owing under the debenture.
        1. This section overrides sections DB 5 to DB 8.

        2. This section overrides the general permission.

        Compare
        Notes
        • Section DB 10 heading: amended, on (not applying, for an income year, to a debenture that a person is party to, if the debenture is issued under an arrangement entered into before 22 November 2013; and a binding ruling on the application of section FA 2(5) was issued to the person in relation to the arrangement; and the binding ruling would continue to apply but for the repeal of the substituting debenture rule by the Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014 (the Act); and for the whole of the income year, the total amount and the term of all debentures issued under the arrangement are not more than those disclosed in the application for the binding ruling; and the person makes an irrevocable election in writing, received by the Commissioner on or before 31 July 2014, that the repeal of the substituting debenture rule in the Act does not apply to their debenture), by section 42(1) of the Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014 (2014 No 39).
        • Section DB 10(2): amended, on (not applying, for an income year, to a debenture that a person is party to, if the debenture is issued under an arrangement entered into before 22 November 2013; and a binding ruling on the application of section FA 2(5) was issued to the person in relation to the arrangement; and the binding ruling would continue to apply but for the repeal of the substituting debenture rule by the Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014 (the Act); and for the whole of the income year, the total amount and the term of all debentures issued under the arrangement are not more than those disclosed in the application for the binding ruling; and the person makes an irrevocable election in writing, received by the Commissioner on or before 31 July 2014, that the repeal of the substituting debenture rule in the Act does not apply to their debenture), by section 42(2) of the Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014 (2014 No 39).
        • Section DB 10 list of defined terms substituting debenture: repealed, on (not applying, for an income year, to a debenture that a person is party to, if the debenture is issued under an arrangement entered into before 22 November 2013; and a binding ruling on the application of section FA 2(5) was issued to the person in relation to the arrangement; and the binding ruling would continue to apply but for the repeal of the substituting debenture rule by the Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014 (the Act); and for the whole of the income year, the total amount and the term of all debentures issued under the arrangement are not more than those disclosed in the application for the binding ruling; and the person makes an irrevocable election in writing, received by the Commissioner on or before 31 July 2014, that the repeal of the substituting debenture rule in the Act does not apply to their debenture), by section 42(3) of the Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014 (2014 No 39).