The proposed changes arising from the government’s review of the rules governing the taxation of corporate debt and derivative contracts are taking shape. Secondary legislation was amended late last year to facilitate the transition to new accounting standards affecting many companies in 2015. Draft legislation detailing the changes to the primary legislation was published for comment shortly after the Autumn Statement. And finally HMRC has made known the general direction of further changes to be introduced later this year.
A primary objective of the proposed changes is to strengthen and clarify the relationship between accountancy and tax in the corporation tax regimes for corporate debt (loan relationships – the LR rules); and for derivative contracts (the DC rules) (CTA 2009 Parts 5 and 7). Currently the...
