Taxation of Loan Relationships and Derivative Contracts, Tenth Edition, is updated in line with the Finance Act 2015 which brings in significant changes to the loan relation rules. In addition, it includes changes to both UK and International Accounting Standards.
This new edition covers developments in the Basic Erosion and Profit Shifting (BEPs) project and the related new climate and wider concept of tax avoidance (GAAR). The chapters covering accounting framework, reorganisations and international aspects have been significantly updated since the previous edition and new chapters have been added with a summary of all relevant cases and a chapter covering Islamic Finance.
Covers the following:
The Taxation of Finance
Accounting under IFRS and Modified UK GAAP
The Scheme of the Legislation
Loan Relationships: Scope and Definition
Loan Relationships: General Computational Provisions
Loan Relationships: Special Computational Provisions
Foreign Exchange and Hedging/Deferral
Reorganisations, Acquisitions and Disposals
Derivative Contracts - Definition and Scope
Derivative Contracts - Measurement of Profits
Worldwide Debt Cap
Stock Lending and Repos
David Southern is a Barrister at Temple Gardens Tax Chambers and specialises in corporate finance. He regularly appears in a wide range of Tax Tribunals and Courts up to and including the European Court of Justice. His advisory work covers most areas of business and personal tax and clients include leading corporates, prominent individuals and political parties.
1 The Taxation of Finance 2 The Accounting Framework 3 The Scheme of the Legislation 4 Loan Relationships: Scope and Definition 5 Loan Relationships: General Computational Provisions 6 Loan Relationships: Special Computational Provisions 7 Impairment Losses 8 Securities 9 Interest 10 Foreign Exchange Gains and Losses 11 Reorganisations, Acquisitions and Disposals 12 Special Companies 13 Derivative Contracts - Definition and Scope 14 Derivative Contracts - Measurement of Profits 15 Embedded Derivatives 16 Hedging and Deferral 17 Case Law 18 Islamic Finance 19 Stock Lending and Repos 20 International Aspects 21 Worldwide Debt Cap Appendix Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2004