I have a project which is based overseas but will be managed and controlled from the UK, so will be taxable here. We are talking to an investor who may want to use some of his pension fund to finance the project. Let's say the pension fund lends the company £24k. The project is potentially high risk and any business angel in such a situation might ask for 4 times his money back (as well as first-born child for security). If we agreed to repay say £100k over 4 years that would be a fantastic return for the pension fund. The profit would be £19k per annum (£25k paid less £6k original loan). Do the rules allow us to do this? Is the loan a deeply discounted security meaning we claim tax relief on the £19k payment each year?!