Commentary

D7.5121 Loan relationships, derivatives and foreign exchange

Corporate tax
Corporate tax | Commentary

D7.5121 Loan relationships, derivatives and foreign exchange

Corporate tax | Commentary

D7.5121 Loan relationships, derivatives and foreign exchange

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

The general principles of FA 1989, s 83 (see D7.599, D7.5100) apply to the income and gains on these asset types given the primacy of that section as a charging section1. The loan relationship regime (see Division D1.7) therefore does not apply for the purposes of calculating a life insurer's trade profit in so far as it applies to creditor relationships, that is loan relationships which

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