Corporation Tax Act 2010

1014Meaning of “hedging arrangements”
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(1)This section explains what “hedging arrangements” means, in relation to a security, in sections 1012 and 1013.

(2)Hedging arrangements” means any scheme or arrangement for the purpose of securing that an offsetting amount of income or gain—

(a)accrues, or

(b)is received or receivable.

(3)In subsection (2) “offsetting amount” means an amount which is intended to offset some or all of the amounts that fall to be brought into account in respect of amounts accruing or falling to be paid in accordance with the terms of the security.

(4)It does not matter whether the purpose mentioned in subsection (2) is the only purpose, or just one of the purposes, of the scheme or arrangement.

(5)It does not matter whether the purpose mentioned in subsection (2) is to secure that the offsetting amount accrues, or is received or receivable, directly or indirectly.

(6)In this section “brought into account” means brought into account in accordance with generally accepted accounting practice.