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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: derivative contracts: tax effect

CFM62700 | Foreign exchange: matching under the Disregard Regulations: derivative contracts: tax effect

From HM Revenue & Customs · Corporate Finance Manual

Effect of regulation 4

Where a derivative contract is matched with an asset, the effect of regulation 4 is to disregard exchange gains or losses on the derivative contract, or as much of the derivative contract as is matched.

The disregarded amounts are brought back into charge as a chargeable gain or loss on disposal of the asset. In certain circumstances, the disregarded amounts are not brought back into account at all, or are brought back as loan relationship credits and debits. The rules at CFM62270 continue to apply for periods beginning on or after 1 January 2005.

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