SCHEDULES
SCHEDULE 7Loan relationships and derivative contracts
Exchange gains and losses
8
In section 451 (exception to section 449 where loan exceeds arm's length amount), after subsection (4) insert—
4A
If the creditor relationship is to any extent matched, subsections (3) and (4) apply to leave out of account only the lesser of—
a
the proportion of the exchange gain or loss which would be left out of account apart from this subsection, and
b
the amount of the exchange gain or loss arising in respect of an asset representing the creditor relationship to the extent that the creditor relationship is unmatched (an amount which may be nil).