Section 354 — Corporation Tax Act 2009: Exclusion of debits for impaired or released connected companies debts

Exclusion of debits for impaired or released connected companies debts 354 1 The general rule is that no impairment loss or release debit in respect of a company's creditor relationship is to be brought into account for the purposes of this Part for an accounting period if section 349 (application of amortised cost basis to connected companies relationship) applies to the relationship for the period.

2 That rule is subject to—

a section 356 (swapping debt for equity),

and b section 357 (insolvent creditors). 2A Where the carrying value of an asset representing the creditor relationship has at any time been adjusted as a result of the asset being the hedged item under a designated fair value hedge, the rule in subsection (1) does not prevent a credit or debit being brought into account for the purposes of this Part in respect of any reversal of that adjustment.

3 Nothing in this section affects the debits to be brought into account for the purposes of this Part in respect of exchange gains or losses arising from a debt.