Section 448 — Corporation Tax Act 2009: Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer

Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer 448 1 This section applies if—

a a company has a debtor relationship in an accounting period, b an exchange gain or loss arises in the period in respect of a liability representing the relationship, and c the whole of any interest or other distribution out of the assets of the company in respect of securities of the company which represent the relationship is regarded as a distribution because of section 1015(6) of CTA 2010 (equity notes held by company associated with issuer or by a funded company).

2 The exchange gain or loss must be left out of account in determining the credits or debits to be brought into account for the purposes of this Part.

3 If the debtor relationship is to any extent matched, subsection (2) applies to leave out of account only the amount of the exchange gain or loss arising in respect of a liability representing the debtor relationship to the extent that the debtor relationship is unmatched (an amount which may be nil).