Corporation Tax Act 2009 section 599B

Determination of credits and debits where amounts not fully recognised

Section 599B sets out how a company must calculate the tax credits and debits for a derivative contract where the amounts have not been fully recognised in the accounts, as identified under section 599A.

  • Credits and debits must be calculated on the assumption that the whole contract is recognised in the company's profit or loss for the period
  • No debits may be brought into account by the company as a result of this section โ€” only credits can arise
  • The credits and debits must be determined using fair value accounting rather than any other basis
  • Where the fair value of the contract at the start of the period exceeds its tax-adjusted carrying value, a credit equal to the difference must be brought into account

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