SCHEDULE 12Trading income provided through third parties: loans etc outstanding on 5 April 2019
Meaning of “outstanding”: quasi-loans in currencies other than sterling
10
(1)
Paragraphs 11 to 14 apply where P makes a quasi-loan to T by reason of acquiring a right to a payment in a particular currency (the “quasi-loan currency”).
(2)
For the purposes of paragraphs 11 to 14, the value of an amount in a particular currency is to be determined by reference to an appropriate spot rate of exchange.
11
(1)
This paragraph applies in relation to the quasi-loan if the quasi-loan currency is a currency other than sterling.
(2)
But this paragraph does not apply if paragraph 14 applies in relation to the quasi-loan.
(3)
The amount of the quasi-loan that is outstanding, at the relevant time, is to be calculated in sterling as follows—
Step 1 Calculate, in the quasi-loan currency, the amount that is outstanding at that time.
Step 2 Take the value in sterling, at that time, of that amount.
(4)
For the purposes of this paragraph and paragraph 14, the “relevant time” in relation to a quasi-loan is the time immediately before the end of 5 April 2019.
(5)
See paragraph 12 for provision about repayments made in a currency other than the quasi-loan currency.