Sections 807B to 807G of ICTA
3451.These amendments insert sections 807B to 807G into ICTA. These sections rewrite double taxation relief provisions in Schedule 9 (loan relationships) to FA 1996 and Schedules 26 (derivative contracts) and 29 (intangible fixed assets) to FA 2002. Those provisions were inserted in those Schedules by The Corporation Tax (Implementation of the Mergers Directive) Regulations (SI 2007/3186) and amended by The Corporation Tax (Implementation of the Mergers Directive) Regulations 2008 (SI 2008/1579).
3452.Because of the similarity of the provisions for each regime (loan relationships, derivative contracts and intangible fixed assets) each section deals with all three regimes.