http://www.legislation.gov.uk/ukpga/2009/4/section/645Corporation Tax Act 2009An Act to restate, with minor changes, certain enactments relating to corporation tax; and for connected purposes.texttext/xmlenStatute Law Database2025-10-17Expert Participation2025-04-01
Corporation Tax Act 2009s. 1094(2A)-(2C)Finance Act 2012Sch. 3 para. 13(3)Corporation Tax Act 2009s. 1106(4A)-(4C)Finance Act 2012Sch. 3 para. 14(3)Corporation Tax Act 2009s. 322(2A)(zb)Finance Act 2016s. 73(5)Corporation Tax Act 2009s. 1058B(5)(ea)Neonatal Care (Leave and Pay) Act 2023Sch. para. 57s. 3(3)reg. 2
Part 7Derivative contractsChapter 7Chargeable gains arising in relation to derivative contracts<Emphasis>Derivative contracts to which sections 640 and 641 apply</Emphasis>Creditor relationships: embedded derivatives which are options6451This section applies to a derivative contract of a company for an accounting period if each of conditions A to E is met.2Condition A is that the derivative contract is a relevant contract to which the company is treated as a party under section 585(2) (loan relationships with embedded derivatives) because of a creditor relationship of the company.3Condition B is that the derivative contract is treated as an option by section 585(3) (contract treated as option, future or contract for differences).4Condition C is that the underlying subject matter of the derivative contract—ais qualifying ordinary shares, orbis mandatorily convertible preference shares.5Condition D is that the company is not a party to the creditor relationship at any time in the accounting period for the purposes of a trade carried on by it.6Condition E is that the company is not an excluded body.7Where this section applies to a derivative contract, the asset representing the creditor relationship is treated for corporation tax purposes as not being a qualifying corporate bond.8See also—asection 647 (meaning of certain expressions in this section), andbsection 670 (treatment of net gains and losses on exercise of option).Pt. 7 modified (with effect in accordance with s. 148 of the amending Act) by Finance Act 2012 (c. 14), s. 88(1)(2)(7) (with s. 147, Sch. 17)Pt. 7 modified by 2007 c. 3, s. 809FZZ(8) (as inserted (with effect in accordance with s. 37(4) of the amending Act) by Finance Act 2016 (c. 24), s. 37(2))Pt. 7 modified (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), ss. 601, 1184(1) (with Sch. 2)