Section 475B — Corporation Tax Act 2009: Meaning of “matched”

Meaning of “matched” 475B 1 This section applies for the purposes of this Part.

2 A loan relationship of a company is matched if and to the extent that—

a it is in a matching relationship with another loan relationship or a derivative contract of the company, or b exchange gains or losses arising in relation to an asset or liability representing the loan relationship are excluded from being brought into account under regulations under section 328(4), and “ unmatched ” is to be construed accordingly.

3 A loan relationship is in a matching relationship with another loan relationship or derivative contract if one is intended by the company to act to eliminate or substantially reduce the economic risk of the other.

4 In this section “ economic risk ” means a risk which can be attributed to fluctuations in exchange rates between currencies over a period of time.

5 In this section “ derivative contract ” has the same meaning as in Part 7 (see section 576).