Commentary

B2.433 Exchange losses following currency fluctuations

Business tax
Business tax | Commentary

B2.433 Exchange losses following currency fluctuations

Business tax | Commentary

B2.433 Exchange losses following currency fluctuations

Where a person borrows in foreign currency and, on repaying the loan, incurs a loss due to the depreciation of sterling against that other currency, the loss is allowable in computing the profits of the trade if the borrowing represents a temporary financial facility used in the carrying on of the trade. If the borrowing by a company forms part of its capital base, such a loss would not, in principle, be deductible as it would represent an item of capital expenditure. This was the decision reached in Marine Midland Ltd1.

For companies the

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