Section 475 — Corporation Tax Act 2009: Meaning of expressions relating to exchange gains and losses

Meaning of expressions relating to exchange gains and losses 475 1 References in this Part to exchange gains or exchange losses, in relation to a company, are references respectively to—

a profits or gains which arise as a result of comparing at different times the expression in one currency of the whole or some part of the valuation put by the company in another currency on an asset or liability of the company, or b losses which so arise.

2 If the result of such a comparison is that neither an exchange gain nor an exchange loss arises, for the purposes of this Part an exchange gain of nil is taken to arise in the case of that comparison.

3 The Treasury may make provision by regulations as to the way in which exchange gains or losses are to be calculated for the purposes of this section ... .

4 The regulations may be made so as to apply to periods of account beginning before the regulations are made, but not earlier than the beginning of the calendar year in which they are made.

5 Any reference in this Part to an exchange gain or loss from a loan relationship of a company is a reference to an exchange gain or loss arising to a company in relation to an asset or liability representing a loan relationship of the company.