Taxation of Loan Relationships and Derivative Contracts

by David Southern

Overview

Taxation of Loan Relationships and Derivative Contracts, Tenth Edition, is updated in line with the Finance Act 2015 which brings in significant changes to the loan relation rules. In addition, it includes changes to both UK and International Accounting Standards.

This new edition covers developments in the Basic Erosion and Profit Shifting (BEPs) project and the related new climate and wider concept of tax avoidance (GAAR). The chapters covering accounting framework, reorganisations and international aspects have been significantly updated since the previous edition and new chapters have been added with a summary of all relevant cases and a chapter covering Islamic Finance.

Covers the following:
The Taxation of Finance
Accounting under IFRS and Modified UK GAAP
The Scheme of the Legislation
Loan Relationships: Scope and Definition
Loan Relationships: General Computational Provisions
Loan Relationships: Special Computational Provisions
Impairment Losses
Foreign Exchange and Hedging/Deferral
Interest
Securities
Reorganisations, Acquisitions and Disposals
Special Companies
Derivative Contracts – Definition and Scope
Derivative Contracts – Measurement of Profits
Embedded Derivatives
Worldwide Debt Cap
Transfer Pricing
Stock Lending and Repos
International Aspects
Islamic Finance
Cases
Appendices

Product Details

ISBN-13:	9781526528667
Publisher:	Bloomsbury Academic
Publication date:	01/16/2025
Edition description:	11th ed.
Pages:	744
Product dimensions:	6.14(w) x 9.21(h) x 1.00(d)

About the Author

David Southern is a Barrister at Temple Gardens Tax Chambers and specialises in corporate finance.
He regularly appears in a wide range of Tax Tribunals and Courts up to and including the European Court of Justice. His advisory work covers most areas of business and personal tax and clients include leading corporates, prominent individuals and political parties.

Table of Contents

1. Company Finance: Debt and Equity
2. The Company Law Framework
3. The Accounting Framework
4. The Scheme of the Legislation
5. Legal Documentation of Debt
6. The Definition of Loan Relationships
7. Loan Relationships: General Computational Provisions
8. Loan Relationships: Special Computational Provisions
9. The Unallowable Purpose Rule
10. Interest
11. Capital Instruments
12. Gilts
13. Transfer Pricing
14. Corporate Interest Restriction
15. Losses
16. Controlled Foreign Companies
17. Special Companies
18. Derivative Contracts - Definition and Scope
19. Derivative Contracts - Computation of Taxable Profits
20. Embedded Derivatives
21. Crypto-assets
22. Foreign Exchange
23. Hedging and Deferral
24. Reorganisations and Reconstructions
25. Stock Lending and Repos
26. Islamic Finance
27. International Aspects