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SCHEDULES

SCHEDULE 21U.K.Foreign exchange: anti-avoidance

CommencementU.K.

11(1)The amendments made by this Schedule have effect—U.K.

(a)in relation to exchange gains and losses arising in accounting periods beginning on or after 22 April 2009, and

(b)subject to the following provisions of this paragraph, in relation to exchange gains and losses arising in straddling accounting periods.

(2)In this paragraph “straddling accounting period” means an accounting period that—

(a)begins before 22 April 2009, and

(b)ends on or after that date.

(3)An exchange gain or loss that arises in a straddling accounting period in relation to—

(a)an asset or liability representing a loan relationship, or

(b)a derivative contract,

is to be treated for the purposes of this paragraph as if it were made up of two amounts.

(4)Those two amounts are the exchange gains or losses that would arise in relation to the loan relationship or derivative contract in—

(a)that part of the period that falls before 22 April 2009, and

(b)that part of the period that falls on or after that date,

if those parts were separate accounting periods.

(5)The amendments made by this Schedule have effect, in relation to an exchange gain or loss of the kind mentioned in sub-paragraph (3), as if the gain or loss were the amount determined in relation to it under sub-paragraph (4)(b).