Corporation Tax Act 2009

185 Change from realisation basis to mark to market

(1) This section applies if there is a change of basis from—

(a) not recognising a profit or loss on an asset until the asset is realised, to

(b) bringing assets into account in each period of account at a fair value.

(2) So far as—

(a) a receipt within item 1 of Step 1 in section 182 represents the fair value of an asset that is trading stock, or

(b) an expense within item 2 of that step relates to such an asset,

the receipt of the trade or (as the case may be) the expense of the trade is treated as not arising until the period of account in which the value of the asset is realised.

(3) In the case of a receipt of the trade, this is subject to any election under section 186 (election for spreading).

(4) In this section “trading stock” has the same meaning as in section 163.