Section 448 | Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer

(1)This section applies if—

(a)a company has a debtor relationship in an accounting period,

(b)an exchange gain or loss arises in the period in respect of a liability representing the relationship, and

(c)the whole of any interest or other distribution out of the assets of the company in respect of securities of the company which represent the relationship is regarded as a distribution because of section 1015(6) of CTA 2010 (equity notes held by company associated with issuer or by a funded company).^F1

(2)The exchange gain or loss must be left out of account in determining the credits or debits to be brought into account for the purposes of this Part.

(3)If the debtor relationship is to any extent matched, subsection (2) applies to leave out of account only the amount of the exchange gain or loss arising in respect of a liability representing the debtor relationship to the extent that the debtor relationship is unmatched (an amount which may be nil).^F2