Modernising the taxation of corporate debt and derivative contracts: update
This Tax Information and Impact Note explains the amendments to the Corporation Tax Act 2009 (CTA 09) that apply to groups of companies.
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This measure will amend the rules in Chapter 4 of Part 5, and Chapter 5 of Part 7, of the Corporation Tax Act 2009 (CTA 09). The changes will amend the ‘de-grouping’ provisions in those chapters that apply when a company to which a loan relationship or derivative contract has been transferred (a ‘transferee company’) ceases to be a member of the group.
This supports the government’s objective of establishing a simpler, more certain and more robust tax system.