CFM9404 - Taxing forex: matching under Disregard Regulations: regulation 3 - matching using loan relationships
When does regulation 3 apply?
This guidance applies to periods of account beginning on or
after 1 January 2005
Regulation 3 deals with loan relationship liabilities matched
with shares, ships or aircraft (provided they are not held for
trading – see
CFM9440) and, more rarely, loan
relationship assets matched with shares.
It does not relate to liabilities that are money debts (such
as a trade debt) on which exchange differences are brought within
FA96/S100(1).
In order for liabilities to be matched to shares, ships or
aircraft either Condition 1 or 2 under regulation 3(3) must apply
– see
CFM9406.
For the conditions for matching of assets with a
company’s own shares see
CFM9442.
