A company may prepare its accounts in a presentation currency other than its functional currency where
This section applies where the functional currency is sterling but a presentation currency other than sterling is used. In this case, the tax rules override what is in the accounts, and profits and losses must be computed by reference to sterling. In computing profits and losses by reference to sterling the company is required to use generally accepted accounting practice by FA98/S42. The company is required to calculate profits and losses as if it had prepared accounts in sterling.
Tychpin Ltd prepares accounts in Euros because it is
consolidated with a parent preparing accounts in Euros. However,
the primary economic environment for Tychpin Ltd is the UK and
sterling is its functional currency. Tychpin therefore identifies
sterling as its functional currency in its accounts. FA93/S92A
applies and Tychpin must calculate its profit or loss by reference
to sterling for UK tax purposes.
Suppose, for example, the accounting records of Tychpin Ltd
show profits of £1,500,000, measured in its functional
currency of sterling. These profits will include any exchange gains
or losses that arise on Euro-denominated assets, liabilities or
transactions. In preparing its accounts, it will translate that
£1,500,000 profit into Euros (either at the spot rate
applicable to each transaction, or at an average rate for the year
where that provides a reasonable approximation). But its tax
computations will need to start from the sterling profit of
£1,500,000, and computational adjustments, capital allowances
and so on will be computed in sterling terms.
This section applies where one currency other than sterling is
the functional currency (as identified by the company in its
accounts) and another currency is used to prepare the accounts.
The company must compute its CT profits or losses by
reference to its functional currency. The profit or loss is then
translated into sterling for tax purposes. For the rate to be used
see
CFM10590.
Where a company translates profits from its functional currency into its presentation currency, exchange differences will arise (and will normally be taken to reserves) – see CFM8026a and CFM8026b for more detail. These exchange differences are ignored in calculating the profit or loss that arises when the profit is computed as if the company had prepared accounts in its functional currency (FA1993/S92A (2) or S92B (2) as appropriate). The tax computations must be based on deemed functional currency accounts, which would not show any such exchange differences.