Commentary

D1.849 Derecognition of derivative contracts

Corporate tax
Corporate tax | Commentary

D1.849 Derecognition of derivative contracts

Corporate tax | Commentary

D1.849 Derecognition of derivative contracts

For times on or after 6 December 2010 a company is not permitted to obtain relief (whether under the derivative contracts legislation or otherwise) for any debits that it recognises in its accounts in accordance with generally accepted accounting practice as a result of a derecognition in whole or in part of, a derivative contract, where the company remains a party to the derivative contract and the derecognition arises as a result of tax avoidance arrangements to which the company is at any time a party1.

For these purposes arrangements are tax avoidance arrangements if the

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