(1)No exchange gains or losses arise for the purposes of this Chapter if the money debt by reference to which the relevant non-lending relationship exists (“the relevant money debt”) is an amount of tax payable under the law of the United Kingdom.
(2)If the relevant money debt is an amount of tax payable under the law of a territory outside the United Kingdom, exchange gains or losses arise for the purposes of this Chapter only so far as a deduction in respect of the tax falls to be made under [F1section 112 of TIOPA 2010] (double taxation relief: deduction for foreign tax where no credit allowable).
(3)No exchange gains or losses arise for the purposes of this Chapter if the relevant money debt is an amount which would be deductible apart from—
(a)a statutory provision other than section 53 (capital expenditure), or
(b)a rule of law.
(4)The reference in subsection (3) to an amount being deductible is a reference to its being deductible—
(a)as an expense in calculating trading profits,
(b)as expenses of management within section 1219 (expenses of management of a company's investment business), or
[F2(c)as ordinary BLAGAB management expenses within the meaning of section 77 of FA 2012 (insurance companies carrying on basic life assurance and general annuity business).]
Textual Amendments
F1Words in s. 486(2) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 91 (with Sch. 9 paras. 1-9, 22)
F2S. 486(4)(c) substituted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 16 para. 162