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Contents

Official guidance
Corporate Finance Manual

CFM57000 · Derivative contracts: hedging

  • CFM57010 · Introduction
  • CFM57030 · Historical overview
  • CFM57040 · Disregard Regulations overview
  • CFM57041 · Change in election approach
  • CFM57050 · Hedging relationship
  • CFM57060 · Hedging relationship: intention
  • CFM57070 · Hedging relationship: HMRC enquiries
  • CFM57071 · Default approach
  • CFM57072 · Regulation 9A
  • CFM57073 · Regulation 9A treatment: example
  • CFM57075 · Hedging: overview of regulations 7, 8 and 9
  • CFM57080 · Regulation 7
  • CFM57090 · When regulation 7 applies
  • CFM57100 · Regulation 7: first example
  • CFM57110 · Regulation 7: no designated hedge
  • CFM57120 · Regulation 7: second example
  • CFM57130 · Regulation 7 and transition
  • CFM57170 · Regulation 10A: bringing into account exchange gains excluded by Regulation 7A
  • CFM57190 · Regulation 13: transitional rules example
  • CFM57200 · Regulation 8
  • CFM57210 · Regulation 10
  • CFM57220 · Regulation 10: examples
  • CFM57230 · Regulation 10: capital expenditure
  • CFM57240 · Regulation 10(3A): example
  • CFM57250 · Regulation 10: more than one cash flow
  • CFM57260 · Regulation 10(5): example
  • CFM57270 · Regulation 10: events not treated as termination events
  • CFM57280 · Regulation 10: ignoring recycling
  • CFM57290 · Regulation 9: interest rate contracts
  • CFM57300 · Regulation 9: scope
  • CFM57310 · Regulation 9: meaning of ‘interest rate contract’
  • CFM57320 · Regulation 9: appropriate accruals basis
  • CFM57330 · Regulation 9: hedge of interest rate risk: example
  • CFM57340 · Regulation 9: just and reasonable adjustments: example
  • CFM57350 · Regulation 9: further examples
  • CFM57360 · Electing into the Disregard Regulations
  • CFM57370 · Electing into regulations 7, 8 and 9
  • CFM57371 · Anti-avoidance
  • CFM57380 · Regulations 6B-6D: transfers within groups
  • CFM57390 · Regulations 6B-6D: transfers within groups: example
  • CFM57400 · Pre-2015: election rules
  • CFM57410 · Pre-2015: regulations 7 and 8 election
  • CFM57420 · Pre-2015: regulations 7 and 8 election: example
  • CFM57430 · Pre-2015: regulation 9 elections
  • CFM57440 · Pre-2015: regulation 9 elections: mandatory treatment
  • CFM57450 · Pre-2015: regulation 9 elections: time limits and effects
  1. Derivative contracts: hedging: contents
  2. Derivative contracts: hedging: Regulation 13: transitional rules example

CFM57190 | Derivative contracts: hedging: Regulation 13: transitional rules example

From HM Revenue & Customs · Corporate Finance Manual

This guidance applies to certain derivative contracts entered into on or after 1 January 2009

Example

A company with a functional currency of US dollars announces a rights issue of sterling shares on 1 February 2009. The rights issue will be made on 1 May 2009.

On 1 February 2009 it hedges the future proceeds against the fluctuations in the £/$ exchange rate through a combination of three forward currency purchase contracts.

On 1 May 2009, when the proceeds are received in sterling, it closes out the forward purchase currency contracts to convert the sterling proceeds into the company’s functional currency of US dollars.

The gains or losses that would have been made on the contracts if an accounting period had ended on 9 March 2009 are as follows:

-Gain - £ millionLoss - £ million
Contract 160-
Contract 2-120
Contract 310

The gains or losses made on the contracts on termination on 1 May 2009 are as follows:

Gain - £ millionLoss - £ million
Contract 180-
Contract 2-100
Contract 3-20

So, the first step is to see which contracts have made a loss and where there is a loss, to identify the lower of the actual loss and the latent loss on 9 March 2009.

  • Contract 1 = No loss

  • Contract 2 = £100 million

  • Contract 3 = £10 million

  • Total = £110 million

The loss that can be brought into account under Regulation 7A cannot exceed the overall loss made on the aggregate of the three contracts on either the date of termination or the latent loss on 9 March 2009.

The total aggregate latent loss on 9 March 2009 is £70M. (i.e. £60M gain less £120M less £10M)

The total aggregate loss on actual termination is £40M (i.e. £80M gain less £100M less £20M)

Therefore, the total loss to be brought into account under Reg 7A is restricted to £40M.

This should be split on a just and reasonable basis between the contracts. The legislation does not define what that basis should be. Generally, however, there would be no necessity to assign the overall loss between individual contracts.

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