Commentary

D1.888 Exactly tracking contracts for differences

Corporate tax
Corporate tax | Commentary

D1.888 Exactly tracking contracts for differences

Corporate tax | Commentary

D1.888 Exactly tracking contracts for differences

In certain cases where a company holds an index-linked loan or loan note that is bifurcated into a host debt contract and an embedded derivative which falls to be treated as a contract for differences for the purposes of the derivative contracts legislation, any profits or losses arising on the embedded derivative will be treated as giving rise to chargeable gains or allowable losses for the purposes of corporation tax on chargeable gains on the basis on which such profits or losses are recognised in the company's accounts1. Such treatment only applies to an

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