The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2004

Made: 9th December 2004

Laid before the House of Commons: 10th December 2004

Coming into force: 1st January 2005

The Treasury, in exercise of the powers conferred upon them by sections 84A(3A), 85B(3)(a) and 85B(5)(b) of the Finance Act 1996[^f00001] and paragraphs 16(3A), 17C(1) and 17C(3)(b) of Schedule 26 to the Finance Act 2002[^f00002] make the following Regulations:

Citation, commencement and effect

1

• (1) These Regulations may be cited as the Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2004 and shall come into force on 1st January 2005.

• (2) These Regulations have effect in relation to periods of account beginning on or after 1st January 2005.

Interpretation

2

• (1) In these Regulations—

• ...

• “CTA 2009” means the Corporation Tax Act 2009;

• “CTA 2010 means the Corporation Tax Act 2010;

• “deferred shares” has the same meaning as in the Building Societies Act 1986;

• “derivative contract” has the same meaning as in Part 7 of CTA 2009;

• “exchange gain or loss” has the same meaning as in section 475 of CTA 2009;

• ...

• “fair value profit or loss” means the profit or loss brought into account in relation to a derivative contract or an asset or liability representing a loan relationship where for the period in question—the derivative contract or asset or liability representing a loan relationship is measured at fair value, orthe derivative contract or asset or liability representing a loan relationship is a hedged item in a designated fair value hedge and the carrying value of the hedged item is adjusted for changes in fair value attributable to the hedged risk;

• “hybrid capital instrument” has the meaning given by section 475C of CTA 2009;

• “loan relationship” has the same meaning as in section 302 of CTA 2009;

• “a section 614 or 615 credit or debit” means the credit or debit to be brought into account in accordance with section 614 or 615 of CTA 2009;

• “a prior period adjustment credit or debit” means so much of any credit or debit as represents a prior period adjustment taken into account by virtue of section 597(1)(b) of CTA 2009 as a result of a change of accounting basis;

• ...

• “underlying subject matter” has the same meaning as in Part 7 of CTA 2009.

• (2) In these Regulations—

• “for accounting purposes” means for the purposes of accounts drawn up in accordance with generally accepted accounting practice;

• “generally accepted accounting practice” has the meaning given in section 1127 of CTA 2010; and

• “amortised cost”, consolidated accounts, “designated”, “effective hedge”, “effective interest method”, “fair value hedge”, “firm commitment”, “forecast transaction”, “foreign operation” , fair value, items of other comprehensive income and “net investment in a foreign operation” have the same meaning as for accounting purposes.

• (3) In these Regulations any reference to an asset which is a ship or aircraft includes a reference to a contract—

• (a) to which section 67 of the Capital Allowances Act 2001[^f00005] applies; and

• (b) which relates to plant or machinery which is a ship or aircraft.

• (3A) For the purposes of these Regulations, a liability representing a loan relationship or a derivative contract is treated as matched with shares, ships or aircraft from the date that, and to the extent that, either condition 1 or 2 of regulation 3(3) or 4(3) are satisfied.

• (4) In these Regulations—

• (a) any reference to a hedging instrument includes a reference to part of an instrument; and

• (b) any reference to a hedged item includes a reference to part of a hedged item.

• (5) For the purposes of these Regulations, a company has a hedging relationship between a derivative contract or a liability representing a loan relationship on the one hand (“the hedging instrument”) and an asset, liability, receipt , expense, forecast transaction or firm commitment on the other (“the hedged item”) if and to the extent that—

• (a) the hedging instrument and the hedged item are designated by the company as a hedge; or

• (b) in any other case the hedging instrument is intended to act as a hedge of—

• (i) the exposure to changes in fair value of a hedged item which is a recognised asset or liability or an unrecognised firm commitment or an identified portion of such an asset, liability or commitment that is attributable to a particular risk and could affect profit or loss of the company;

• (ii) the exposure to variability in cash flows that is attributable to a particular risk associated with a hedged item that is a recognised asset or liability or a forecast transaction and could affect profit or loss of the company; or

• (iii) a net investment in a foreign operation of the company.

• (6) For the purposes of regulations 3 to 5, where an asset referred to is shares in a company, the asset comprises all the shares held in that company whenever acquired.

Exchange gains or losses arising from liabilities or assets hedging shares etc.

3

• (1) For the purposes of section 328(4) of CTA 2009 there is prescribed an exchange gain or loss arising to a company in an accounting period in relation to a liability representing a loan relationship of the company which is matched with the whole or part of any shares, ships or aircraft.

• (1ZA) But where the matched shares, ships or aircraft are matched after the company became party to the loan relationship, paragraph (1) only applies to a just and reasonable proportion of any exchange gain or loss having regard to—

• (a) the fraction of the accounting period for which the shares, ships or aircraft are matched with the loan relationship,

• (b) the fraction of the accounting period for which the company was party to the loan relationship, and

• (c) fluctuations in exchange rates during the accounting period.

• (1A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (2) This regulation does not apply if movements in the fair value , or profits or losses arising on the disposal, of any shares, ships or aircraft which are an asset falling within regulation 3(1) are brought into account by the company in computing, for the purposes of corporation tax, the profits of a trade carried on by it which consists of or includes dealing in shares, ships or aircraft.

• (3) Shares, ships or aircraft are matched to the greatest possible extent with—

...

Condition 1The condition is that ... the shares, ships or aircraft are a hedged item under a designated hedge of exchange rate risk in which the liability is the hedging instrument.

Condition 2The condition is that the currency in which the liability is expressed is such that the company intends, by entering into or continuing to be subject to that liability, ... to eliminate or substantially reduce the economic risk of holding the asset, or part of the asset, which is attributable to fluctuations in exchange rates.

• (4) If condition 2 applies, a liability is matched with an asset only to the extent that the carrying value of the liability ... does not exceed the unmatched carrying value of the asset at the relevant time.

• (5) For the purposes of section 328(4) of CTA 2009 there is prescribed an exchange gain or loss arising to a company in an accounting period in relation to an asset representing a loan relationship of the company which is matched with the whole or part of—

• (a) any share capital of the company,

• (b) in relation to a building society, any deferred shares issued by the building society to the extent that they are accounted for as equity instruments in accordance with generally accepted accounting practice, or

• (c) a hybrid capital instrument issued by the company to the extent that it is accounted for as an equity instrument in accordance with generally accepted accounting practice.

• (6) An asset is matched with share capital in particular where for the accounting period of the company immediately preceding the first accounting period to which these Regulations apply—

• (a) exchange gains and losses on the asset were taken to a reserve; and

• (b) set off there against exchange gains and losses on the share capital.

• (7) In this regulation—

• “carrying value” means, in relation to a liability, the relevant value of that liability; and

• “unmatched carrying value” means, in relation to an asset, an amount equal to the value as shown in the company’s accounts to the extent that that amount has not previously been matched in accordance with this regulation or regulation 4.

Condition 1

The condition is that for the accounting period of the company immediately preceding the first accounting period to which these Regulations apply—

• (a) exchange gains and losses on the shares, ships or aircraft were taken to a reserve; and

• (b) set off there against exchange gains and losses on the liability.

Condition 2

The condition is that for the accounting period, the shares, ships or aircraft are a hedged item under a designated hedge of exchange rate risk in which the liability is the hedging instrument.

Condition 3

The condition is that the currency in which the liability is expressed is such that the company could, by entering into that liability, reasonably expect to eliminate or substantially reduce the economic risk of holding the asset, or part of the asset, which is attributable to fluctuations in exchange rates.

• (4) If condition 3 applies, a liability is matched with an asset only to the extent that the carrying value of the liability at the time when the liability is entered into does not exceed the unmatched carrying value of the asset at that time.

• (5) For the purposes of section 84A(3A) of the Finance Act 1996 there is prescribed an exchange gain or loss arising to a company in an accounting period in relation to an asset representing a loan relationship of the company which is matched with the whole or part of any share capital of the company.

• (6) An asset is matched with share capital if for the accounting period of the company immediately preceding the first accounting period to which these Regulations apply—

• (a) exchange gains and losses on the asset were taken to a reserve; and

• (b) set off there against exchange gains and losses on the share capital.

• (7) In this regulation—

• “carrying value” means, in relation to a liability, the value as shown in the company’s accounts of that liability; and

• “unmatched carrying value” means, in relation to an asset, an amount equal to the value as shown in the company’s accounts to the extent that that amount has not previously been matched in accordance with this regulation or regulation 4.

Exchange gains or losses arising from derivative contracts hedging shares etc.

4

• (1) For the purposes of section 606(4) and 598(1)(a) of CTA 2009 there is prescribed an exchange gain or loss arising to a company in an accounting period in relation to a derivative contract of the company which is matched with the whole or part of any shares, ships or aircraft.

• (1A) But where the matched shares, ships or aircraft are matched after the company became party to the derivative contract, paragraph (1) only applies to a just and reasonable proportion of any exchange gain or loss having regard to—

• (a) the fraction of the accounting period for which the shares, ships or aircraft are matched with the derivative contract,

• (b) the fraction of the accounting period for which the company was party to the derivative contract, and

• (c) fluctuations in exchange rates during the period.

• (2) This regulation does not apply if movements in the fair value , or profits or losses arising on the disposal, of any shares, ships or aircraft which are an asset falling within regulation 4(1) are brought into account by the company in computing, for the purposes of corporation tax, the profits of a trade carried on by it which consists of or includes dealing in shares, ships or aircraft.

• (3) Shares, ships or aircraft are matched to the greatest possible extent with—

...

Condition 1The condition is that ... the shares, ships or aircraft are a hedged item under a designated hedge of exchange rate risk in which the derivative contract is the hedging instrument.

Condition 2The condition is that the underlying subject matter of the derivative contract is such that the company intends, by entering into or continuing to be party to that contract, ... to eliminate or substantially reduce the economic risk of holding the asset, or part of the asset, which is attributable to fluctuations in exchange rates.

• (4) If condition 2 applies, a derivative contract is matched with an asset only to the extent that the value of the obligation under the derivative contract ... does not exceed the unmatched carrying value of the asset at the relevant time.

• (4A) For the purposes of section 606(4) of CTA 2009 there is prescribed an exchange gain or loss arising to a company in an accounting period in relation to a derivative contract of the company which is matched with the whole or part of—

• (a) any share capital of the company,

• (b) in relation to a building society, any deferred shares issued by the building society to the extent that they are accounted for as equity instruments in accordance with generally accepted accounting practice, or

• (c) a hybrid capital instrument issued by the company to the extent that it is accounted for as an equity instrument in accordance with generally accepted accounting practice.

• (4B) A derivative contract is matched with share capital in particular where for the accounting period of the company immediately preceding the first accounting period beginning on or after 1st January 2005—

• (a) exchange gains and losses on the derivative contract were taken to a reserve; and

• (b) set off there against exchange gains and losses on the share capital.

• (4C) This regulation does not apply to amounts in relation to a derivative contract which are excluded amounts under regulation 5ZA.

• (5) In this regulation—

• ...

• “unmatched carrying value” means, in relation to an asset, an amount equal to the relevant value to the extent that that amount has not previously been matched in accordance with this regulation or regulation 3.

• “the value of the obligation under the derivative contract” means the value of the obligation of the company to pay in exchange for one currency an amount of a second currency and includes any notional obligation to pay an amount of currency in respect of a contract for differences.

Condition 1

The condition is that for the accounting period of the company immediately preceding the first accounting period to which these Regulations apply—

• (a) exchange gains and losses on the shares, ships or aircraft were taken to a reserve; and

• (b) set off there against exchange gains and losses on the derivative contract.

Condition 2

The condition is that for the accounting period, the shares, ships or aircraft are a hedged item under a designated hedge of exchange rate risk in which the derivative contract is the hedging instrument.

Condition 3

The condition is that the underlying subject matter of the derivative contract is such that the company could, by entering into that contract, reasonably expect to eliminate or substantially reduce the economic risk of holding the asset, or part of the asset, which is attributable to fluctuations in exchange rates.

• (4) If condition 3 applies, a derivative contract is matched with an asset only to the extent that the carrying value of the derivative contract at the time when the contract is entered into does not exceed the unmatched carrying value of the asset at that time.

• (5) In this regulation—

• “carrying value” means, in relation to a derivative contract, the value as shown in the company’s accounts of that contract; and

• “unmatched carrying value” means, in relation to an asset, an amount equal to the value as shown in the company’s accounts to the extent that that amount has not previously been matched in accordance with this regulation or regulation 3.

Regulations 3 and 4: supplementary

5

• (1) Where in any accounting period—

• (a) a company holds more than one asset in relation to which there are amounts of exchange gains and losses falling within regulations 3 or 4; and

• (b) the currency—

• (i) in which the assets are denominated and the liability mentioned in regulation 3(1) expressed; or

• (ii) which is the underlying subject matter of the derivative contract mentioned in regulation 4(1) ,

is the same currency, ... the extent to which an asset is matched is determined in accordance with the following rules.

Rule 1 Liabilities and contracts are regarded as matched to the greatest possible extent with assets which are ships or aircraft.

Rule 2Subject to Rule 1, liabilities and contracts are regarded as matched to the greatest possible extent with assets on the disposal of which a chargeable gain would accrue if the disposal were made on a date falling more than 12 months after the date of acquisition of the asset.

Rule 3Subject to Rules 1 and 2, liabilities and contracts are regarded as matched with assets on a disposal of which no chargeable gain would be treated as accruing by virtue of Part 1 of Schedule 7AC to the Taxation of Chargeable Gains Act 1992[^f00006] ....

• (2) If—

• (a) part only of a liability falling within the third condition in regulation 3, or

• (b) part only of a contract falling within the third condition in regulation 4,

could reasonably be expected to eliminate or substantially reduce the economic risk of holding the asset which is attributable to fluctuations in exchange rates, the liability or contract is to be treated as being matched with a corresponding amount of value of an asset.

• (3) For the purposes of paragraph (1), a currency in which a liability is expressed or which is the underlying subject matter of a derivative contract, is to be treated, if it is not the case, as the same currency in which an asset is denominated if—

• (a) borrowing in that currency, or

• (b) the obligation to deliver that currency,

could reasonably be expected to eliminate or substantially reduce the economic risk of holding the asset, or part of the asset, which is attributable to fluctuations in exchange rates.

• (4) Where regulation 3 or section 328(3) of CTA 2009 applies to a company in an accounting period in relation to a liability representing a loan relationship there is prescribed, for the purposes of regulation 3 or section 328(4) of that Act, an exchange gain or loss treated by virtue of section 192(1) of the Taxation (International and Other Provisions) Act 2010 as arising in that accounting period to another company in relation to the same loan relationship.

Rule 1

Liabilities and contracts are regarded as matched to the greatest possible extent with assets which—

• (a) represent loan relationships of the company;

• (b) represent derivative contracts of the company; or

• (c) are ships or aircraft.

Rule 2

Subject to Rule 1, liabilities and contracts are regarded as matched to the greatest possible extent with assets on the disposal of which a chargeable gain would accrue.

Rule 3

Subject to Rules 1 and 2, liabilities are regarded as matched with assets on a disposal of which no chargeable gain would be treated as accruing by virtue of Part 1 of Schedule 7AC to the Taxation of Chargeable Gains Act 1992[^f00006] if the disposal were made on a date falling more than twelve months after the date of the acquisition of the asset.

• (2) If—

• (a) part only of a liability falling within the third condition in regulation 3, or

• (b) part only of a contract falling within the third condition in regulation 4,

could reasonably be expected to eliminate or substantially reduce the economic risk of holding the asset which is attributable to fluctuations in exchange rates, the liability or contract is to be treated as being matched with a corresponding amount of value of an asset.

• (3) For the purposes of paragraph (1), a currency in which a liability is expressed or which is the underlying subject matter of a derivative contract, is to be treated, if it is not the case, as the same currency in which an asset is denominated if—

• (a) borrowing in that currency, or

• (b) the obligation to deliver that currency,

could reasonably be expected to eliminate or substantially reduce the economic risk of holding the asset, or part of the asset, which is attributable to fluctuations in exchange rates.

• (4) Where regulation 3 or section 84A(3) of the Finance Act 1996 applies to a company in an accounting period in relation to a liability representing a loan relationship there is prescribed, for the purposes of regulation 3 or section 84A(3A) of that Act, an exchange gain or loss treated by virtue of paragraph 6D(2) of Schedule 28AA to the Taxes Act 1988[^f00007] as arising in that accounting period to another company in relation to the same loan relationship.

Rules about fair value profits and losses

6

• (1) Regulation 7, 8 or 9 apply in relation to a derivative contract (which satisfies the conditions in regulation 7(1)(a), 8(1)(a) or 9(1), as the case may be) if—

• (a) an election under regulation 6A has effect in relation to the contract,

• (b) the contract or part of the contract is a designated fair value hedge,

• (c) the hedged item is a loan relationship in relation to which the company uses fair value accounting, or

• (d) the contract forms part of an arrangement the main purpose, or one of the main purposes, of which is to obtain a tax advantage in relation to that contract that would not arise if regulation 7, 8 or 9 applies.

• (2) In paragraph (1)(d)—

• “arrangement” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable);

• “tax advantage” has the meaning given in section 1139 of CTA 2010.

Fair value profits or losses arising from derivative contracts which are currency contracts

7

• (1) For the purposes of section 598(1)(a) of CTA 2009 there is prescribed in relation to a derivative contract whose underlying subject matter consists wholly of currency —

• (a) all credits and debits representing the whole or part of a company’s fair value profit or loss in an accounting period if—

• (i) there is a hedging relationship between the contract or part of the contract and a forecast transaction or a firm commitment (“the hedged item”) of the company; and

• (ii) the hedged item is not one for which fair value profits or losses are brought into account for the purposes of corporation tax;

• (b) a company’s section 614 or 615 credit or debit in relation to such a contract, if for the accounting period in which the section 614 or 615 credit or debit falls to be brought into account sub-paragraph (a) applies to the contract; and

• (c) a company’s prior period adjustment credit or debit in relation to such a contract, if for the accounting period in which the prior period adjustment credit or debit falls to be brought into account sub-paragraph (a) applies to the contract,

and the credits and debits mentioned in sub-paragraphs (a) to (c) together make up the regulation 7 fair value profits or losses.

• (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (3) Where there is a hedging relationship between part of a currency contract and a hedged item, the part of the regulation 7 fair value profit or loss that is prescribed is the part which bears to the whole the proportion which the value of that part of the contract which is in the hedging relationship bears to the value of the whole of the contract.

• (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (5) Where regulation 4 or 5ZA applies to a contract to which this regulation applies, nothing in this regulation or regulation 10 is to require any amount prescribed under regulation 4 or excluded under 5ZA in relation to that contract to be brought into account.

Profits or losses arising from derivative contracts which are commodity contracts or debt contracts

8

• (1) For the purposes of section 598(1)(a) of CTA 2009 there is prescribed in relation to a commodity contract or debt contract—

• (a) all credits and debits representing the whole or part of a company’s fair value profit or loss arising in an accounting period if—

• (i) there is a hedging relationship between the contract or part of the contract and a forecast transaction or a firm commitment (“the hedged item”) of the company; and

• (ii) the hedged item is not one for which fair value profits or losses are brought into account for the purposes of corporation tax;

• (b) a company’s section 614 or 615 credit or debit, if for the accounting period in which the section 614 or 615 credit or debit falls to be brought into account, sub-paragraph (a) applies to the contract; and

• (c) a company’s prior period adjustment credit or debit, if for the accounting period in which the prior period adjustment credit or debit falls to be brought into account, sub-paragraph (a) applies to the contract,

and the credits and debits mentioned in sub-paragraphs (a) to (c) together make up the regulation 8 fair value profits or losses.

• (2) In this regulation—

• “a commodity contract” means a derivative contract whose underlying subject matter is commodities unless the contract is an interest rate contract within the meaning of regulation 9(4); and

• “a debt contract” means a derivative contract whose underlying subject matter is an asset or liability representing a loan relationship unless the contract is an interest rate contract within the meaning of regulation 9(4).

• (3) Where there is a hedging relationship between part of a commodity contract or part of a debt contract as the case may be and a hedged item, the part of the regulation 8 fair value profit or loss that is prescribed is the part which bears to the whole the proportion which the value of that part of the contract which is in the hedging relationship bears to the value of the whole of the contract.

Profits or losses arising from derivative contracts which are commodity contracts or debt contracts

9

• (1) For the purposes of section 598(1)(a) of CTA 2009 there is prescribed all credits and debits representing the whole or part of the fair value profit or loss arising to a company in relation to its interest rate contracts in an accounting period if—

• (a) there is a hedging relationship between the contract or a portion of the contract and any of the risks arising in respect of an asset, liability, receipt or expense (“the hedged item”); and

• (b) fair value profits or losses arising on the hedged item or in relation to any of the risks , in relation to which the contract was intended to act as a hedge, arising in respect of the hedged item, or any portion of the hedged item, are not brought into account for the purposes of corporation tax for that period.

• (2) Where paragraph (1) applies, credits and debits shall be brought into account for the purposes of section 598(1)(b) of CTA 2009 on the assumption that an appropriate accruals basis had been used in relation to the contract for that accounting period.

• (2A) Where an interest rate contract—

• (a) becomes a contract to which paragraph (1) applies, or

• (b) ceases to be a contract to which paragraph (1) applies,

the amount to be brought into account for the purposes of section 598(1)(b) of CTA 2009 is such amount as is just and reasonable in the circumstances and with regard to whether as a result of the change any amounts cease to be brought into account or are brought into account more than once and to the unexpired term of the hedged item.

• (3) Where regulation 4 or 5A apply to a contract to which this regulation applies nothing in this regulation is to require any exchange gains or losses in relation to that contract to be brought into account.

• (4) In this regulation—

• “an appropriate accruals basis” in relation to a derivative contract is one where—the contract is shown in the company’s accounts at cost (which may be nil), and the cost is adjusted for any cumulative amortisation of any premium or other amount falling to be recognised in arriving at the cost of the contract;the aggregate of—the amount of periodical payments under the contract, or in the case of a swap contract under which only a single payment is to be made, the value of the payment andthe credits or debits representing interest arising, on the assumption that an effective interest method is used, in respect of the asset or liability representing a loan relationship which is the hedged item,represent the credits or debits that would be given by generally accepted accounting practice in relation to an asset or liability representing a loan relationship whose terms include those of both the hedged item and the interest rate contract;exchange gains and losses are recognised as a result of the translation of the contract at the balance-sheet date; andprofits and losses which arise as a result of the contract coming to an end before its stated date of maturity are amortised and brought into account over the unexpired term of the hedged item.

• “an interest rate contract” means—a derivative contract whose underlying subject matter is, or includes, interest rates, orif not falling within paragraph (i), a swap contract in which payments fall to be made by reference to a rate of interest or to an index determined by reference to income or retail prices.

• (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• (7) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Bringing fair value profits or losses into account on currency and commodity contracts

10

• (1) For the purposes of section 598(1)(c) of CTA 2009 —

• (a) there is prescribed the aggregate of the credits and debits representing any regulation 7 or 8 fair value profits or losses excluded in relation to a derivative contract of a company ...; and

• (b) the amount of that aggregate is brought into account for the period in which a termination event occurs.

Signed

Derek Twigg — Nick Ainger — Two of the Lords Commissioners of Her Majesty’s Treasury — 9th December 2004

Explanatory note

(This note is not part of the Regulations)

These Regulations allow certain profits and losses from loan relationships and derivative contracts to be left out of account, to be brought into account in a different way or to be brought into account at a later date.

Regulation 1 provides for the citation, commencement and effect.

Regulation 2 provides for the interpretation.

Regulation 3 prescribes for exchange gains or losses arising from liabilities hedging shares etc. to be disregarded where the contract is matched with shares, ships or aircraft.

Regulation 4 prescribes for exchange gains or losses arising from derivative contracts hedging shares etc. to be disregarded where the contract is matched with shares, ships or aircraft.

Regulation 5 contains provisions supplementary to regulations 3 and 4.

Regulation 6 introduces, in relation to fair value profits and losses, specific rules which are contained in regulations 7, 8 and 9 and in particular provides for the rules in those regulations to be subject to elections.

Regulation 7 prescribes fair value profits and losses arising from derivative contracts which are currency contracts.

Regulation 8 prescribes bringing fair value profits and losses into account on commodity contracts and debt contracts.

Regulation 9 prescribes profits or losses arising from derivative contracts which are interest rate contracts.

Regulation 10 brings into account profits or losses arising on currency and commodity contracts.

These Regulations do not impose any new costs on business.

Footnotes

[^f00001]: 1996 c. 8. Section 84A was inserted by paragraph 3 of Part 1 of Schedule 23 to the Finance Act 2002 (c. 23) and sub-section (3A) was substituted by paragraph 2(2) of Schedule 10 to the Finance Act 2004 (c. 12) (“the 2004 Act”). Sections 85B was substituted and inserted by paragraph 3 of Schedule 10 to the 2004 Act.

[^f00002]: 2002 c. 23. Paragraph 16(3A) was substituted by paragraph 48(2), and paragraphs 17C(1) and 17C(3)(b) were substituted by paragraph 50, of Part 2 of Schedule 10 to the 2004 Act.

[^f00005]: 2001 c. 2.

[^f00006]: 1992 c. 12. Part 1 was inserted by paragraph 1 of Part 1 of Schedule 8 to the Finance Act 2002.

Exchange gains or losses arising from derivative contracts hedging shares etc.

Regulations 3 and 4: supplementary

Rules about fair value profits and losses

Fair value profits or losses arising from derivative contracts which are currency contracts

Profits or losses arising from derivative contracts which are commodity contracts or debt contracts

Profits or losses arising from derivative contracts which are commodity contracts or debt contracts

Bringing fair value profits or losses into account on currency and commodity contracts

Editorial notes

[^key-bdbd59a33c484580e1abaa772ae60f99]: Reg. 1 in force at 1.1.2005, see reg. 1(1)

[^key-10b8e70f05c2091ba1c2ca1d9312e975]: Reg. 2 in force at 1.1.2005, see reg. 1(1)

[^key-ed0d3ecad92392b2ea91bb7e2950821d]: Reg. 3 in force at 1.1.2005, see reg. 1(1)

[^key-66701c209a6da5079524833cf16f46c9]: Reg. 4 in force at 1.1.2005, see reg. 1(1)

[^key-694d0799629766212ee18f41df3a50e9]: Reg. 5 in force at 1.1.2005, see reg. 1(1)

[^key-5681458b22e407093f756be5bdd3a92a]: Reg. 7 in force at 1.1.2005, see reg. 1(1)

[^key-ace23226d2688d5cefdb4c9259219c45]: Reg. 8 in force at 1.1.2005, see reg. 1(1)

[^key-83c88bc0c42f251ccddd127eab8764cd]: Reg. 9 in force at 1.1.2005, see reg. 1(1)

[^key-de8e8e0b116162417161f2ee7bb8c510]: Reg. 10 in force at 1.1.2005, see reg. 1(1)

[^key-02693990729046ce49d949fbdf7e1d2d]: Words in reg. 2(1) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 3(a)

[^key-c0b9cc4c29172f0648c88ed61e89ae7d]: Words in reg. 2(1) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 3(b)

[^key-003d51e061f4647d7a35a969ab79b4a2]: Words in reg. 3(2) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(3)

[^key-7a75e8010415b0b142f3c0f4cbddd2c2]: Words in reg. 3(3) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(a)

[^key-67848f38627615a4e4ea29eb53b16bf0]: Words in reg. 3(3) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(b)

[^key-134f1ab23e45f725dd6a34426dfd0dc6]: Word in reg. 3(3) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(c)(i)

[^key-b91bf536f6bd4f3bf2787239abc4cc93]: Words in reg. 3(3) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(c)(ii)

[^key-426c8ecb466b703494fcac1d2d2f98cb]: Words in reg. 3(3) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(c)(iii)

[^key-24d8cc97a544a86a051602c64f96bec2]: Reg. 3(3): Condition 2 renumbered as Condition 1 (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(d)(i)

[^key-93ccc8bd26995a174c4a75df3459d6f0]: Reg. 3(3): Condition 3 renumbered as Condition 2 (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(4)(d)(ii)

[^key-a7e562b532d9d61c2d43103b4a84c1ff]: Words in reg. 3(4) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 4(5)(a)

[^key-a9f6d77236e114e891c168816995fe58]: Words in reg. 4(2) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(2)

[^key-ae754e4419c7522bc9a1d29e15576401]: Words in reg. 4(3) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(a)

[^key-5b2f6b29d9840c3c5fa94dcdc64f5246]: Words in reg. 4(3) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(b)

[^key-c53309f2fd2ecf7aab6eac5e23236a25]: Word in reg. 4(3) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(c)(i)

[^key-1b3e9746261483d4c377352990ecdfc7]: Words in reg. 4(3) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(c)(ii)

[^key-d2f86d8ae09196a3e499e2229702bd0e]: Words in reg. 4(3) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(c)(iii)

[^key-56a57514ef95bddeff4b8b4ad0958a21]: Reg. 4(3): Condition 2 renumbered as Condition 1 (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(d)(i)

[^key-baddacaae6b3a897c45386427dfd0098]: Reg. 4(3): Condition 3 renumbered as Condition 2 (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(3)(d)(ii)

[^key-281364a91c2edeea834a5116198899fe]: Words in reg. 4(4) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(4)(a)

[^key-0db16b0b34a9e2f139663fc8e48fd060]: Words in reg. 4(4) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(4)(b)

[^key-97ff3fe7968671504ce681ce9b7ec4fc]: Words in reg. 4(5) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(5)(a)

[^key-c352f70fc925390506b48cc73f81d60f]: Words in reg. 4(5) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 5(5)(b)

[^key-fcdda0dcc2810eaf5080c7e7c15622c4]: Words in reg. 5(1)(b)(i) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(2)(a)

[^key-dfb53378b630af93b12bb2db8542c4b7]: Words in reg. 5(1)(b)(ii) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(2)(b)

[^key-7d143793df6d7d3d75e0c29b0605de67]: Words in reg. 5(1)(b) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(2)(c)

[^key-19b1188c24aca090f4ef142fe92918d9]: Words in reg. 5(1) added (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(3)

[^key-299b606bdf74c2a3207c927e8d75364d]: Words in reg. 5(1) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(4)

[^key-55f378d006a9d25a568af5b31486d209]: Words in reg. 5(1) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(5)

[^key-edf93cd36c27d0deb087d5efb69d51fa]: Words in reg. 5(1) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(6)(a)

[^key-113cbbe60faba0d7de730f4e0eec06ec]: Words in reg. 5(1) revoked (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 6(6)(b)

[^key-db46e682996b30a93feda676a30f49e4]: Reg. 7(1) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 8(2)

[^key-1b13601c8a120116b968e5b8a82326de]: Reg. 7(2) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 8(3)

[^key-2e16563c9144d44d3f450f2952b91f47]: Words in reg. 7(3) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 8(4)

[^key-4de7e6cd2553ed252e615d220dab58c0]: Reg. 8(1) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 9(2)

[^key-88496a85f7057e8607b6c3728ab19ffb]: Words in reg. 8(3) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 9(3)

[^key-1c5716e34d3da0d7e2e180f3c21b9153]: Words in reg. 10(1)(a) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(2)(a)

[^key-2ed5ab6238d65c738dac373f2fbcdb65]: Words in reg. 10(1)(a) omitted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(2)(b)

[^key-207ddf5e4faa861393d79ad8cb10c748]: Words in reg. 10(3) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(3)

[^key-94f1530561a893ea8d273f3b8250fe8b]: Reg. 10(3A) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(4)

[^key-605fc04afdb3dedebe89d174ab7ae1ad]: Words in reg. 10(5) inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(5)

[^key-8be1b0a0d5fb49415680e0fd59008e0b]: Word in reg. 10(6)(a) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(6)(a)

[^key-70ba011fa898bb2273911f3606873c0d]: Words in reg. 10(6)(b) substituted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 10(6)(b)

[^key-018ef03962316334af4acdfed2c16fbd]: Regs. 11, 12 inserted (11.8.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2005 (S.I. 2005/2012), regs. 1(1), 11

[^key-5b8e1f7e0f75d29a59656817d729901e]: Words in reg. 3(7) substituted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 3

[^key-4c76c1240223f1e632b9de15f1d8b8f0]: Words in reg. 3(6) substituted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 4

[^key-3b56f7fc71d53187449cc1efb4d3bca6]: Reg. 4(4A)(4B) inserted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 5

[^key-a7a97529f7f8d0fe678c4f8997655ac4]: Words in reg. 4(5) substituted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 3

[^key-b815e3f5946ce0f1370214e963947255]: Words in reg. 7(1)(a)(ii) substituted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 8

[^key-1df64d2aa78d1936fc0204d8cd0c9287]: Words in reg. 8(1)(a)(ii) substituted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 8

[^key-f87c29d08d13a70162673053434e2206]: Reg. 9(2A) inserted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 9

[^key-85306294b258f7027bd743cd6d38255c]: Words in reg. 10(3A) inserted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 11(2)

[^key-31a046715bbe0c9c5beaab73b77bd4ea]: Reg. 10(3B)(3C) inserted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 11(3)

[^key-a0f8d63942d3ae3b3b2108e55202c5ca]: Reg. 11(4) inserted (29.11.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 12

[^key-4d390a3bc812eab8b96e1aa91799433a]: Reg. 12(3)(4) inserted (29.12.2005 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2005 (S.I. 2005/3374), regs. 1(1), 13(4)

[^key-617349c3902a118eaff71a969badb276]: Words in reg. 9(1)(b) inserted (27.12.2006 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2006 (S.I. 2006/3236), regs. 1(1), 4

[^key-49cc05ff31929bdc237aa4cd1bc038d7]: Reg. 11(1)(1A) substituted for reg. 11(1) (27.12.2006 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2006 (S.I. 2006/3236), regs. 1(1), 6(2)

[^key-d7a8c4cb3c345ec254fdd57a1b4c1d4d]: Words in reg. 11(2)(b) inserted (27.12.2006 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2006 (S.I. 2006/3236), regs. 1(1), 6(3)

[^key-03ff41424114a8afb07554a23ed3b84c]: Words in reg. 11(3)(b) inserted (27.12.2006 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2006 (S.I. 2006/3236), regs. 1(1), 6(4)

[^key-6fae0a10eccdb139118697fc24024614]: Reg. 12(1)-(2A) substituted for reg. 12(1)(2) (27.12.2006 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2006 (S.I. 2006/3236), regs. 1(1), 7(2)

[^key-49062032593a75c8a43f6348a7d7089d]: Regs. 4A-4C substituted for reg. 4A (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(5)

[^key-1f94f84de3ab7407c7b337b42e1b4a71]: Words in reg. 2(2) inserted (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(2)(a)

[^key-dc2916719daab4fd03078507e265e6c7]: Reg. 2(6) inserted (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(2)(b)

[^key-d40a465c810dad9112380f9eb7d37615]: Words in reg. 3(4) omitted (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(3)(a)

[^key-cc5913e4336713528aadf6fb300ef7c8]: Words in reg. 3(4) substituted (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(3)(b)

[^key-2bc9b4cc8a5ed8bd5423bd65a7cf4e8b]: Words in reg. 4(4) omitted (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(4)(a)

[^key-01a3b34dafe971318a517a914ff4d1ea]: Words in reg. 4(4) substituted (27.12.2007 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2007 (S.I. 2007/3431), regs. 1(1), 2(4)(b)

[^key-acdfe840950bc7c963f45a2a007a9c6f]: Reg. 7A inserted (5.8.2009 with application and effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2009 (S.I. 2009/1886), regs. 1(1), 5 (with reg. 7)

[^key-1b7f12d43eec04a81df9646948c302ab]: Reg. 10A inserted (5.8.2009 with application and effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2009 (S.I. 2009/1886), regs. 1(1), 6

[^key-dddc0685c1361f30d8df4f9c7cd5efe1]: Reg. 13 inserted (5.8.2009 with application and effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2009 (S.I. 2009/1886), regs. 1(1), 7

[^key-c793a5c83fda1f7b94e92c91a65a7e70]: Word in reg. 4(3) substituted (1.4.2011 in relation to accounting periods beginning on or after that date) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2011 (S.I. 2011/698), regs. 1, 4

[^key-7d0f8af073df203884bb3b78ce1d79e1]: Word in reg. 3(3) substituted (1.4.2011 in relation to accounting periods beginning on or after that date) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2011 (S.I. 2011/698), regs. 1, 3

[^key-03920b139e3c2ead6f2cc459c0897c79]: Second reg. 4A(6) renumbered as reg. 4A(9) (1.4.2011 in relation to accounting periods beginning on or after that date) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2011 (S.I. 2011/698), regs. 1, 5(4)

[^key-a9b827d2da089d901130b4400859b9c5]: Reg. 4C substituted (1.4.2011 in relation to accounting periods beginning on or after that date) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2011 (S.I. 2011/698), regs. 1, 6

[^key-a2ab13b9e886eaa6ee6791fe82db00d1]: Reg. 2(3A) inserted (6.12.2011 at 11.45 a.m. with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2011 (S.I. 2011/2912), regs. 1(1), 3

[^key-fd2d8719e406f9298961b1a3dc581c40]: Reg. 3(1ZA) inserted (6.12.2011 at 11.45 a.m. with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2011 (S.I. 2011/2912), regs. 1(1), 4(1)

[^key-f91f7b85a9efd106f2bcf7bedcb4ad74]: Words in reg. 3(3) omitted (6.12.2011 at 11.45 a.m. with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2011 (S.I. 2011/2912), regs. 1(1), 4(2)

[^key-2c36503f37b3d14cd6b3552e86900a1e]: Reg. 4(1A) inserted (6.12.2011 at 11.45 a.m. with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2011 (S.I. 2011/2912), regs. 1(1), 5(1)

[^key-015af052d05eaf8ac2ce47204334de2b]: Words in reg. 4(3) omitted (6.12.2011 at 11.45 a.m. with effect in accordance with reg. 1(2) of the amending S.I.) by virtue of The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment No. 2) Regulations 2011 (S.I. 2011/2912), regs. 1(1), 5(2)

[^key-b23955115536a9f20c14aa63e6f314e0]: Words in reg. 2(1) inserted (21.11.2013 with effect in accordance with reg. 1(2) of the amending S.I.) by The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2013 (S.I. 2013/2781), regs. 1(1), 2(2)