Commentary

D1.864 Matching—identification rules

Corporate tax
Corporate tax | Commentary

D1.864 Matching—identification rules

Corporate tax | Commentary

D1.864 Matching—identification rules

The extent to which a derivative contract is treated as matching shares, ships or aircraft is determined in accordance with a rule-based approach.

The rule-based approach applies to both loan relationships and currency contracts1 where a company holds more than one asset in relation to which there are amounts of exchange gains and losses which are eligible for matching treatment under the Disregard Regulations2, and a debtor loan relationship is denominated in, or the currency which is the underlying subject matter of the currency contract, is the same, or an economically equivalent currency, as that in which the

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