Corporation Tax Act 2009 section 699

Priority of this Part for corporation tax purposes

Section 699 establishes that Part 7 (derivative contracts) takes priority over other corporation tax provisions when determining the amounts to be brought into account.

• Where amounts relating to derivative contracts are brought into account under Part 7, those are the only amounts that may be recognised for corporation tax purposes in respect of that matter
• This priority rule applies not only to credits and debits calculated under the main computational rules but also to amounts dealt with under the special provisions in Chapter 7
• There are specific exceptions where this priority is overridden, including the disapplication of fair value accounting for certain derivative contracts and transitional rules for plain vanilla contracts that became derivative contracts before 30 December 2006
• Where Part 5 (loan relationships) applies to particular amounts, those amounts are not brought into account under Part 7, and so this priority rule does not come into play for them