Explanatory Notes

Corporation Tax Act 2010

2010 CHAPTER 4

3 March 2010

Introduction

Part 23: Company distributions

Chapter 2: Matters which are distributions
Section 1014: Meaning of “hedging arrangements”

3005.This section defines “hedging arrangements” for the purposes of sections 1012 and 1013. It is based on section 209B(8) of ICTA.

3006.The “hedging arrangements” are looked at from the point of view of the issuing company. The essence of the definition is that there is an amount of income or gain that offsets amounts that the company has to meet in relation to the security.