Commentary

D1.861A Hedging proceeds of a rights issue or an open offer of shares

Corporate tax
Corporate tax | Commentary

D1.861A Hedging proceeds of a rights issue or an open offer of shares

Corporate tax | Commentary

D1.861A Hedging proceeds of a rights issue or an open offer of shares

Where a company enters into a currency forward contract1 to hedge the exchange exposure arising from a rights issue or open offer of shares that are issued in a currency other than its functional currency, any fair value profits or losses that arise on the forward contract will be disregarded in computing its derivative contract profits, to the extent that the contract is hedging the proceeds of the rights issue or open offer2. The company will, however, be liable to tax on any fair value profits arising

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