The Exchange Gains and Losses (Debts of Varying Amounts) Regulations 1994
These Regulations, which come into force on 23rd March 1995, insert a new section 136A into the Finance Act 1993. The new section supplements section 136 of the Finance Act 1993, which provides for the “ring-fencing” of exchange losses (by preventing relief otherwise than by set-off against future exchange gains on the same loan) where a loan is entered into on non-arm’s length terms.