Introduction Background Note
7.At Budget 2013 the Government announced a review of the legislation governing the taxation of corporate debt (‘loan relationships’) and derivative contracts.  The aim of the review is to make the legislation simpler and more certain, as well as more resistant to abuse. A consultation document Modernising the taxation of corporate debt and derivative contracts was published in June 2013, and the Government’s response to the consultation was published in December 2013.
8.The consultation document reviewed and set out proposals for changes to a wide range of the provisions relating to loan relationships and derivative contracts, including a change to the de-grouping rules.
9.Subject to further consultation, it is envisaged that most of these changes will be enacted in Finance Bill 2015. However, some changes will be made in Finance Act 2014, including the change in this measure.