David Boneham examines the state of play on the proposals to modernise the taxation of corporate debt and derivative contracts
The government announced in Budget 2013 a review of the law governing the corporation tax treatment of corporate debt (loan relationships) and derivative contracts. The object was to make the legislation simpler and more certain as well as more resistant to abuse. A consultation process was launched in June 2013. Whilst most reform of the primary legislation is to occur in Finance Bill (FB) 2015 the government indicated from the outset that some measures would be dealt with in FB 2014. The draft legislation relating to the treatment of loan relationships held by corporate partnerships and that relating to ‘bond funds’ (in CTA 2009 Part 6 Chapter 3) are now the only such...
