Commentary

D1.887 Shares are acquired—provision to prevent double counting

Corporate tax
Corporate tax | Commentary

D1.887 Shares are acquired—provision to prevent double counting

Corporate tax | Commentary

D1.887 Shares are acquired—provision to prevent double counting

Where a company acquires shares as a result of the exercise of an option embedded in a loan relationship to which CTA 2009, ss 645, 646 apply (see D1.886), or as a result of the exercise of a stand-alone option which falls to be dealt with under the provisions of the derivative contracts legislation, measures apply to ensure that there is no double counting of any profits or losses that have been taken into account for tax purposes under the derivative contracts legislation.

Embedded options

In the case of options which are bifurcated from a creditor loan

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