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Corporation Tax Act 2009

Existing assets representing creditor relationships: contracts for differences

3542.This paragraph and the next one make, with one exception, corresponding provision in respect of a derivative contract and its host contract, if section 648 (creditor relationships: embedded derivatives which are exactly tracking contracts for differences) would apply to the derivative contract but for the disapplication in the preceding paragraph, to that made by the paragraphs above for “existing assets representing creditor relationships: options”. The exception is that these paragraphs do not provide specially for exchange gains and losses (“relevant exchange gains” and “relevant exchange losses” in the earlier paragraphs). These paragraphs are based on paragraphs 12(11C) and (11D) and 45FA(1), (2), (3), (4) and (5) of Schedule 26 to FA 2002.

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