Section 673 — Corporation Tax Act 2009: Meaning of G, L and CV in section 672

Meaning of G, L and CV in section 672 673 1 This section applies for the purposes of section 672.

2 G is the sum of the amounts of any chargeable gains treated as accruing to the company under section 641(3)(a) (derivative contracts to be taxed on a chargeable gains basis) in respect of the derivative contract in each relevant accounting period.

3 L is the sum of the amounts of any allowable losses treated as accruing to the company under section 641(3)(b) in respect of the derivative contract in each relevant accounting period.

4 CV is the amount by which the tax-adjusted carrying value of the host contract at the date of the disposal exceeds the tax-adjusted carrying value of that contract at the date on which the company became a party to the creditor relationship mentioned in section 648(2).

5 In this section— “ the host contract ” means the loan relationship to which the company is treated as a party under section 415(2) (loan relationships with embedded derivatives) because of the creditor relationship mentioned in section 648(2), and “ relevant accounting period ” means— the accounting period in which the disposal is made, or any previous accounting period.