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Taxation (International and Other Provisions) Act 2010
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46Applying section 44(2): asset in hedging relationship with derivative contract
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(1)If an asset is in a hedging relationship with a derivative contract, section 44(2) applies in relation to the asset as if the income arising from the asset is the income arising from the asset and the contract taken together, subject to subsection (2).
(2)Take account of the income or loss from the derivative contract only so far as reasonably attributable to the hedging relationship.
(3)For the purposes of subsection (1), an asset is in a hedging relationship with a derivative contract if—
(a)the asset is acquired as a hedge of risk in connection with the contract, or
(b)the contract is entered into as a hedge of risk in connection with the asset.
(4)If an asset or a contract is wholly or partly designated as a hedge for the purposes of a person’s accounts, that is conclusive for the purposes of subsection (3).
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