The Exchange Gains and Losses (Bringing into Account Gains or Losses) (Amendment) Regulations 2010
These Regulations amend the Exchange Gains and Losses (Bringing into Account Gains or Losses) Regulations 2002, S.I. 2002/1970 (“the principal Regulations”). The principal Regulations provide for exchange gains or losses on loans or derivatives which hedge foreign exchange risk from a company’s investment in a foreign enterprise, and which have previously been disregarded for corporation tax purposes, to be brought back into account in specified circumstances. These amendments change the way in which this is achieved. The purpose of doing so is to eliminate anomalies in the interaction between the principal Regulations and the Taxation of Chargeable Gain Act 1992 (“the 1992 Act”).