Hedging of tax-interest expense amounts or tax-interest income amounts etc
3(1)Section 387 (relevant derivative contract credits) is amended as follows.
(2)In subsection (3), for paragraph (c) substitute—
“(c)it is in respect of a risk arising in the ordinary course of a trade (other than a risk arising in the ordinary course of a financial trade) where the derivative contract was entered into wholly for reasons unrelated to the capital structure of the worldwide group (or any member of the worldwide group).”
(3)After subsection (3) insert—
“(3A)For the purposes of subsection (3)(c) a credit is in respect of a risk arising in the ordinary course of “a financial trade” only so far as the risk relates to an amount which is or is likely to be—
(a)a tax-interest expense amount, or
(b)a tax-interest income amount,
of the company in any relevant accounting period.”