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Contents

Official guidance
Corporate Finance Manual

CFM62600 · Foreign exchange: matching under the Disregard Regulations

  • CFM62610 · Overview
  • CFM62620 · Why special rules are needed
  • CFM62630 · Regulation 3: matching using loan relationships
  • CFM62640 · Conditions 1 and 2
  • CFM62650 · Condition 2: examples
  • CFM62660 · Loan relationships: tax effect
  • CFM62670 · Extent of matching: regulation 3(4)
  • CFM62680 · Regulation 4: matching using derivatives
  • CFM62690 · Regulation 4(4): matching extent
  • CFM62700 · Derivative contracts: tax effect
  • CFM62710 · Relevant value
  • CFM62720 · Relevant value: example
  • CFM62730 · Periods beginning on or after 1 January 2008
  • CFM62740 · Meaning of net asset value
  • CFM62750 · Currency of foreign operation
  • CFM62760 · Ascertaining net asset value
  • CFM62770 · Meaning of net asset value: examples
  • CFM62780 · Higher of accounts and net asset value
  • CFM62790 · Meaning of relevant time
  • CFM62800 · Review periods: examples
  • CFM62810 · Bringing amounts back into account
  • CFM62820 · Order of matching: regulation 5
  • CFM62830 · Thin capitalisation
  • CFM62840 · Trading assets
  • CFM62850 · Foreign exchange: matching under Disregard Regulations: matching own share capital
  1. Foreign exchange: matching under the Disregard Regulations: contents
  2. Foreign exchange: matching under the Disregard Regulations: regulation 3: matching using loan relationships

CFM62630 | Foreign exchange: matching under the Disregard Regulations: regulation 3: matching using loan relationships

From HM Revenue & Customs · Corporate Finance Manual

When does regulation 3 apply?

Regulation 3 deals with loan relationship liabilities matched with shares, ships or aircraft (provided they are not held for trading) and, more rarely, loan relationship assets matched with shares.

It does not relate to liabilities that are money debts (such as a trade debt) on which exchange differences are brought within CTA09/S481.

In order for liabilities to be matched to shares, ships or aircraft either Condition 1 or 2 under regulation 3(3) must apply - see CFM62640.

For the conditions for matching of assets with a company’s own shares see CFM62850.

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