SCHEDULES

SCHEDULE 12U.K.Trading income provided through third parties: loans etc outstanding on 5 April 2019

Meaning of “outstanding”: quasi-loans in currencies other than sterlingU.K.

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”).U.K.

(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.U.K.

(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.