Corporation Tax Act 2010 section 1014

Meaning of "hedging arrangements"

Section 1014 defines what "hedging arrangements" means in relation to a security, for the purposes of sections 1012 and 1013 which deal with certain distributions involving such arrangements.

• Hedging arrangements are any scheme or arrangement designed to secure an offsetting amount of income or gain that either accrues or is received or receivable.
• An offsetting amount is one intended to offset some or all of the amounts that must be brought into account in respect of sums accruing or payable under the terms of the security.
• The hedging purpose does not need to be the sole purpose of the scheme — it can be just one of several purposes.
• It does not matter whether the offsetting amount accrues or is received directly or indirectly.