SCHEDULES
SCHEDULE 21Foreign exchange: anti-avoidance
Commencement
11
1
The amendments made by this Schedule have effect—
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).