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Derivatives and complex financial instruments: an introduction

Mandipa Soni and Edward Brown (Grant Thornton) discuss the taxation of loan relationships and derivatives for UK corporates, with a focus on convertible securities from the borrower’s perspective.

As we approach Christmas many tax advisors will be turning an eye to the delivery of their corporation tax compliance obligations whilst supporting treasury functions and the wider business manage the existing challenges of Brexit and the continued fall-out from covid-19. For most this means a focus on managing cash flow and liquidity with many companies using complex financial instruments to meet their commercial needs. Whilst such financial instruments may allow greater flexibility for both the Borrower and Lender the tax consequences of these instruments can require a little more consideration than usual to ensure the right treatment is applied.

Common themes that are becoming more prevalent are the use...

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