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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: extent of matching: regulation 3(4)

CFM62670 | Foreign exchange: matching under the Disregard Regulations: extent of matching: regulation 3(4)

From HM Revenue & Customs · Corporate Finance Manual

Limits of matching

This rule prevents the matching of an asset with a liability of greater value. It aims to replicate the accounting rule under SSAP 20 where any excess exchange difference on the liability was taken to profit and loss rather than reserves and taxed accordingly.

Where condition 2 applies (CFM62640), a loan relationships liability is treated as matched with an asset to the extent that the carrying value of the liability on acquisition or when the asset is acquired, if later, does not exceed the carrying value of the asset. For periods of account beginning on or after 1 January 2008, however, a loan relationships liability is treated as matched with an asset to the extent that the carrying value of the liability does not exceed the carrying value of the asset at ‘the relevant time’ (see CFM62790). CFM62710 explains what is meant by ‘carrying value’.

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