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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.8 Derivative contracts /Computation of relevant debits and credits / D1.861 Interest rate contracts
Commentary

D1.861 Interest rate contracts

Corporate tax

This provision applies where a company uses all or part of an interest rate contract in order to hedge an underlying transaction. An interest rate contract is defined as:

  1. Ìý

    (a)ÌýÌýÌýÌý a derivative contract whose underlying subject matter is, or includes, interest rates. It will thus be noted that the definition goes far wider than what would generally be considered to be an interest rate contract, such as an interest rate swap, forward rate agreement or an interest rate future; or

  2. Ìý

    (b)ÌýÌýÌýÌý in a case not falling within head (a) above, a swap contract in which payment falls to be made by reference to a rate of interest or to an index determined by reference to income or retail prices1.

Where this provision applies, credits and debits representing the whole or part of the fair value profit or loss arising to the company in respect of the interest rate contract for an accounting period are left out of account in computing its profit or loss for the purposes of the derivative contracts legislation provided:

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