Commentary

D1.866 Matching—anti-avoidance

Corporate tax
Corporate tax | Commentary

D1.866 Matching—anti-avoidance

Corporate tax | Commentary

D1.866 Matching—anti-avoidance

The measures that are discussed in this article were repealed with effect for arrangements entered into on or after 18 November 2015.

For arrangements entered into before 18 November 2015, it is not possible for an exchange gain or loss arising on a derivative contract, whose underlying subject matter includes currency, or a loan relationship to be treated as matched where it forms part of an arrangement between connected companies that is designed to achieve one-way matching. To explain this anti-avoidance provision it is necessary to look at how matching is often structured within groups of companies.

Typically the company seeking matching treatment (matching company) will borrow from or enter into a currency contract with a connected company (and in certain cases there may be a chain of loans or currency contracts between connected companies ending ultimately with the matching company). In such cases if an exchange gain arises to the matching company on a group basis this would enable the group to obtain relief for the exchange loss arising on the

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