HMRC has published a new chapter in its Corporate finance manual to cover new reg 5ZA of the Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Loss) Regulations, SI 2004/3256. The new reg 5ZA in the Disregard Regulations applies to derivative contracts entered into on or after 1 April 2022 and operates to remove the mismatch in tax treatment where a derivative contract is used to hedge the foreign exchange risk relating to a prospective share transaction. The new guidance is set out at CFM62900 onwards.
HMRC has published a new chapter in its Corporate finance manual to cover new reg 5ZA of the Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Loss) Regulations, SI 2004/3256. The new reg 5ZA in the Disregard Regulations applies to derivative contracts entered into on or after 1 April 2022 and operates to remove the mismatch in tax treatment where a derivative contract is used to hedge the foreign exchange risk relating to a prospective share transaction. The new guidance is set out at CFM62900 onwards.
