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A loan note is a type of financial instrument; it is a contract for a loan that specifies when the loan must be repaid and usually also the interest payable. It is similar to a promissory note but the differences can be significant in terms of consequences, especially tax consequences. Chief of these is that by specifying the interest payable, the lender may obtain a tax shield. Loan notes are simple but important instruments in business and finance. A loan note can also be conceived of as a form of deferred payment, and in the UK the tax treatment of loan notes is as either ‘qualifying corporate bonds’ (QCBs), which provide a tax shield, or as ‘non-qualifying corporate bonds’ (non-QCBs) Loan notes may contain other provisions such as convertibility into equity or other kinds of debt, in w

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