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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: meaning of net asset value

CFM62740 | Foreign exchange: matching under the Disregard Regulations: meaning of net asset value

From HM Revenue & Customs · Corporate Finance Manual

How net asset value matching works

Where a company holds shares in another company (referred to in the legislation as ‘company A’), and those shares are matched with a liability or derivative contract under condition 2 of regulation 3 or regulation 4, regulation 4A defines ‘net asset value’ in relation to those shares.

It is the value of the assets, less the value of the liabilities that are

  • owned by company A itself, or by a direct or indirect subsidiary of A, and

  • denominated in the relevant currency (see CFM62750).

‘Relevant currency’ means the currency giving rise to the foreign exchange risk referred to in regulation 3(3) and regulation 4(3) - the currency to which the company is exposed.

‘Subsidiary’ should be accorded the meaning that it has for accounting purposes, in other words a subsidiary of company A is any entity (including an unincorporated entity such as a partnership) that is controlled by A.

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