½Û×ÓÊÓÆµ

Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.8 Derivative contracts /Taxation treatment of debits and credits / D1.893 Debtor relationship—embedded equity instrument
Commentary

D1.893 Debtor relationship—embedded equity instrument

Corporate tax

As noted in D1.892, where a debtor loan relationship, which carries rights of conversion into the issuer's own shares, is bifurcated into a host contract and an equity instrument, the equity instrument falls outside the derivative contracts legislation. Despite this, provision is made to permit an issuer to obtain relief for a loss suffered in respect of an equity instrument as an allowable loss where it redeems or repurchases

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial

Web page updated on 17 Mar 2025 13:35