Corporation Tax Act 2009 section 639

Overview of Chapter

Section 639 provides an overview of Chapter 7, which deals with situations where profits and losses from certain derivative contracts are taxed as chargeable gains rather than being treated as income.

• Certain derivative contracts are removed from the normal income-based tax treatment and are instead taxed under the chargeable gains regime
• Four types of derivative contract receive chargeable gains treatment: contracts relating to land or tangible movable property, embedded derivative options in creditor relationships, exactly tracking contracts for differences in creditor relationships, and property-based total return swaps
• Bespoke chargeable gains rules also apply to embedded derivatives in debtor relationships, covering both options and contracts for differences
• Chapter 8 contains further rules that apply or modify the chargeable gains regime in a range of additional situations