Commentary

D7.438 Loan relationships, derivative contracts and intangible fixed assets

Corporate tax
Corporate tax | Commentary

D7.438 Loan relationships, derivative contracts and intangible fixed assets

Corporate tax | Commentary

D7.438 Loan relationships, derivative contracts and intangible fixed assets

The rules in this division apply for accounting periods beginning on or after 1 January 2013. For accounting periods beginning before 1 January 2013 see Division D7.5.

The general rules for the taxation of loan relationships in CTA 2009, Pt 5 (see Division D1.7), derivative contracts in CTA 2009, Pt 7 (see Division D1.8) and intangible assets in CTA 2009, Pt 8 (see Division D1.6) apply in calculating the BLAGAB I-E profit of life insurance companies with some modifications. Notwithstanding the fact that an insurance company is party to these arrangements as part of its insurance trade, any credits and debits referable to BLAGAB are brought into account as non-trading debits or credits1.

The company's acceptable commercial allocation method (see D7.432) will determine what part of any debit or credit arising from a loan relationship, derivative contract or intangible fixed asset of the

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial