Section 938O — Corporation Tax Act 2010: Losses and profits from tax mismatch scheme to be disregarded

Losses and profits from tax mismatch scheme to be disregarded 938O 1 This section applies to a company that is (at any time) a party to a tax mismatch scheme.

2 No scheme loss or profit made by the company in any accounting period in relation to the scheme is to be brought into account as a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts).

3 An amount that would, apart from this section, be brought into account for the purposes of Part 5 or 7 of that Act as respects any matter—

a is treated, for the purposes of section 464(1) or (as the case may be) 699(1) of that Act (priority of Part 5 or 7 for corporation tax purposes), as if it were so brought into account, and b accordingly, may not be brought into account for any other corporation tax purposes as respects that matter.