CTM76610 - Exchange differences: matching: liability becoming matched during accrual period

Where there is major change in the extent to which a liability is matched with an asset during an accrual period and there is a significant change in exchange rates in that period then Regulation 5(3)(c) SI1994/3227 provides that the time of that change is treated as a translation time as regards that liability. This enables tax treatment to mirror accounting treatment.

Example

A company with a 30 June accounting date borrows $500,000 on 1 September 1996 when $500,000 = £300,000. On 1 January 1997 the company acquires a $500,000 holding of shares in an overseas subsidiary and makes a matching election to apply from that date. At 1 January 1997 $500,000 = £350,000. At 30 June 1997 $500,000 = £280,000.

Under the normal accounting rules (ignoring matching) an exchange gain of £20,000 accrues on the liability (£300,000 at 1 September 1996 less £280,000 at 30 June 1997). Applying the alternative method of calculation would involve accruing the gain evenly over the period and leaving out the amount relating to the period from 1 January 1997 to 30 June 1997 when the loan was matched. The net result would be:

  • a net gain of 4/10 x £20,000 = £8,000, and
  • a matched gain of 6/10 x £20,000 = £12,000.

However, to mirror the accounting treatment, 1 January 1997 is treated under Regulation 5(3) as a translation time. An exchange loss of £50,000 accrues on the loan for the accrual period from 1 September 1996 to 1 January 1997. An exchange gain of £70,000 accrues on the loan for the accrual period from 1 January 1997 to 30 June 1997.

As the matching election covers the period from 1 January 1997 to 30 June 1997 the exchange gain of £70,000 is reduced to nil. The exchange loss of £50,000, which accrued when the liability was not matched, is unaffected.

Inspectors should look critically at cases where a computational adjustment is made on the basis of the alternative method of calculation that does not reflect accounting treatment.