The rules comprising the corporate interest restriction are lengthy and complex. To assist the reader, this Practice Note starts with a background section and a short,...
The general rule is that: • the credits (broadly, but not necessarily, profits), and • debits (broadly, but not necessarily, losses) arising to a company from its...
The general rule is that: • the credits (broadly, but not necessarily, profits), and • debits (broadly, but not necessarily, losses) arising to a company from its...
Certain securities and contracts do not naturally fall within just one of the loan relationships regime or the derivative contracts regime. In addition, some contracts...
Certain securities and contracts do not naturally fall within just one of the loan relationships regime or the derivative contracts regime. In addition, some contracts...
The derivative contracts regime in Part 7 of the Corporation Tax Act 2009 (CTA 2009) calculates a company's taxable profits (and losses available for relief) arising from...
The derivative contracts rules: • form a self-contained, exclusive, regime for the taxation of a company's income, profits and gains (and relief for losses) arising from...
FORTHCOMING CHANGE relating to transfers within an EU group: Finance Bill 2019–20 will contain provisions permitting companies to pay tax in instalments in relation to...
The general position is, broadly, that the derivative contracts regime taxes (ie brings into account for corporation tax purposes) the: • credits—broadly, the receipts...
This Practice Note sets out rules that apply to periods of account beginning before 1 January 2015. In such periods, where certain conditions were met, the Disregard...
This Practice Note sets out rules that apply to periods of account beginning before 1 January 2015. In such periods, where certain conditions were met, the Disregard...
Hedging is the mechanism by which a company will mitigate certain risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or •...
Hedging is a mechanism used by companies to mitigate certain risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or • the...
A company will most commonly enter a hedge arrangement to mitigate risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or...
A company will most commonly enter a hedge arrangement to mitigate risks and exposures which, broadly, have the potential to impact either: • the company's cash flow, or...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The derivative contracts regime forms a self-contained, exclusive, regime for the taxation of a company's income, profits and gains (and relief for losses) arising from...
The general rule is that the derivative contracts regime form a self-contained, exclusive, set of rules for the taxation of a company's holdings of derivative financial...
The general rule is that: • the loan relationships regime forms a self-contained, exclusive, regime for the taxation of corporate debt (ie very broadly, a company's...
The general rule is that: • the loan relationships regime forms a self-contained, exclusive, regime for the taxation of corporate debt (ie very broadly, a company's...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The derivative contracts rules: • form a self-contained, exclusive, regime for the taxation of a company's income, profits and gains (and relief for losses) arising from...
What is the concept behind the EU FTT? The original Financial Transaction Tax (FTT or ‘Tobin tax’) Directive proposal (published in September 2011) was a very...
The derivative contracts rules are a self-contained regime governing the taxation of a company’s profits and losses arising from its derivative contracts. The rules are...