SCHEDULES
SCHEDULE 16Exchange gains and losses: transitionals
Miscellaneous
6
1
Regulations may provide—
a
that provision under paragraph 3 above or provision under paragraph 4 above or provision under neither of them shall apply in the case of an asset or liability according to the circumstances of the case;
b
that provision under paragraph 3(3)(a) above or provision under paragraph 3(3)(b) above shall apply in the case of an asset or liability according to the circumstances of the case.
2
The circumstances may be framed by reference to—
a
whether, and how, exchange differences arising as regards the asset or liability would be taken into account for tax purposes apart from this Chapter;
b
such other factors as the Treasury think fit;
and for this purpose exchange differences are gains and losses attributable to fluctuations in currency exchange rates.