The European Single Currency (Taxes) Regulations 1998

Debt contracts (including options)—conversion into euro

11.—(1) Where as a result of the adoption of the euro by a member State—

(a) there is a euroconversion of the loan relationship to which, under a debt contract, a qualifying company has any entitlement, or is subject to any duty, to become a party, or

(b) a qualifying company has any entitlement, or is subject to any duty, to become treated as a person with rights and liabilities corresponding to those of a party to a loan relationship and there is a euroconversion of any of those rights and liabilities, and

(c) in either of the cases referred to in sub-paragraphs (a) and (b) the effect is that the original debt contract is rescinded and replaced by a new debt contract,

the new debt contract shall be treated for the purposes of section 150A of the Finance Act 1994(1) (debt contracts and options) as if it were the same contract as the original debt contract, made when the original debt contract was made.

(2) In paragraph (1)—

• “debt contract” has the meaning given by section 150A(1) and (2) of the Finance Act 1994;

• “loan relationship” has the meaning given by section 81 of the Finance Act 1996, read with section 150A(10) of the Finance Act 1994;

• “qualifying company” shall be construed in accordance with section 154 of the Finance Act 1994.

(1)

Section 150A was inserted by Schedule 12 to the Finance Act 1996.