Commentary on Sections Overview Overview Section 448: Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer
1292.This section applies where interest is to be treated as a distribution under section 209(2)(e)(vii) of ICTA. It is based on paragraph 11A(1) of Schedule 9 to FA 1996. Exchange gains and losses on the security giving rise to that interest are left out of account in computing gains under this Part in respect of the debtor company.