Article 54 - Balancing Payments by Guarantor
(1) This Article applies where—
(a) the circumstances are as described in Article 52(1);
(b) one or more payments (the "balancing payments") are made by the guarantor person to the borrowing person; and
(2) To the extent that the balancing payments by all the guarantor persons do not in aggregate exceed the total amount of the reductions as mentioned in Article 52(3), those payments shall not be taken into account in computing the
Chargeable Profits or tax losses of the guarantor person or persons or the borrowing person.