Commentary

D1.734 Loan relationships—Matching: bringing amounts into account

Corporate tax
Corporate tax | Commentary

D1.734 Loan relationships—Matching: bringing amounts into account

Corporate tax | Commentary

D1.734 Loan relationships—Matching: bringing amounts into account

Regulations have been made to provide for the exchange gains and losses which have been treated as matched (and so excluded from tax computations) to be brought into account for tax purposes in the accounting period in which the disposal of the matched asset takes place. Identification rules apply to determine the extent to which an asset is matched.

Exchange movements arising on a debtor loan relationship are treated as matched with an asset where:

  1.  

    •     exchange movements on the debtor loan relationship and an asset have both been recognised in the company's statement of changes in equity or statement of recognised gains and losses in accordance with generally accepted accounting practice or

  2.  

    •     where the loan relationship is treated as matched with an asset under reg 5 of the Disregard Regulations1 (see 'Identification rules' at D1.732)

Where a debtor loan relationship is treated as matched against assets on a disposal of which a chargeable gain would arise the consideration for the disposal of the asset is increased by the amount of any net matched gain and is reduced by the amount of any net matched loss. Where the net matched loss exceeds the disposal consideration the excess is treated as

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