»Ê¹ÚÌåÓýapp

FA 2009: the ‘one-way exchange effect provision�

»Ê¹ÚÌåÓýapp Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2006 - SI 2006/843) which aimed to counter particular ‘one-way betâ€� schemes (CFM63010) were revoked by FA09, and replaced by a more widely targeted anti-avoidance rule (‘TAARâ€�), which prevents exchange gains from being matched where a ‘one-way exchange effectâ€� is present. »Ê¹ÚÌåÓýapp details of this rule are explained at CFM63120. onwards.

Commencement

»Ê¹ÚÌåÓýapp new anti-avoidance rule applies to accounting periods beginning on or after 22 April 2009. Accounting periods straddling 22 April 2009 are treated as if they were two periods, with exchange gains and losses being computed separately for each period. »Ê¹ÚÌåÓýapp restriction on matching exchange gains applies to the part-period beginning on 22 April 2009, but not to the earlier part of the accounting period.

»Ê¹ÚÌåÓýapp commencement rule at FA09/SCH21/PARA11 also applies to the old regulations so they apply to a part-period up to 22 April 2009, but not subsequently.