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House of Commons

Session 2008 - 09 Internet Publications Other Bills before Parliament

Corporation Tax Bill

Corporation Tax Bill xxix
592    Embedded derivatives treated as meeting condition in section 591 etc
593    Contracts where part of underlying subject matter is excluded property
Chapter 3
Credits and debits to be brought into account: general
Introduction
594    Overview of Chapter
General principles
595    General principles about the bringing into account of credits and debits
596    Meaning of “related transaction”
Amounts recognised in determining a company’s profit or loss
597    Amounts recognised in determining a company’s profit or loss
598    Regulations about recognised amounts
599    Meaning of “amounts recognised for accounting purposes”
Application of fair value accounting
600    Contract which is or forms part of financial asset or liability
601    Contract relating to holding in OEIC, unit trust or offshore fund
602    Contract becoming one relating to holding in OEIC, unit trust or offshore
fund
603    Associated transaction treated as derivative contract
Rules differing from generally accepted accounting practice
604    Credits and debits treated as relating to capital expenditure
605    Credits and debits recognised in equity
Miscellaneous
606    Exchange gains and losses
607    Pre-contract or abortive expenses
608    Company ceasing to be party to derivative contract
609    Company ceasing to be UK resident
610    Non-UK resident company ceasing to hold derivative contract for UK
permanent establishment
611    Release under statutory insolvency arrangement of liability under derivative
contract
Chapter 4
Further provision about credits and debits to be brought into account
Introduction
612    Overview of Chapter
Corporation Tax Bill xxx
Adjustments on change of accounting policy
613    Introduction to sections 614 and 615
614    Change of accounting policy involving change of value
615    Change of accounting policy after ceasing to be party to derivative contract
Certain embedded derivatives
616    Disapplication of fair value accounting
617    Election for section 616 not to apply
618    Elections under section 617: groups of companies
Partnerships involving companies
619    Partnerships involving companies
620    Determination of credits and debits by company partners
621    Company partners using fair value accounting
Miscellaneous
622    Contracts ceasing to be derivative contracts
623    Index-linked gilt-edged securities with embedded contracts for differences
Chapter 5
Continuity of treatment on transfers within groups
Introductory
624    Introduction to Chapter
Group member replacing another as party to derivative contract
625    Group member replacing another as party to derivative contract
626    Transactions to which section 625 applies
627    Meaning of company replacing another as party to derivative contract
Exceptions to section 625
628    Transferor using fair value accounting
629    Tax avoidance
Transferee leaving group after replacing transferor as party to derivative contract
630    Introduction to sections 631 and 632
631    Transferee leaving group otherwise than because of exempt distribution
632    Transferee leaving group because of exempt distribution
Chapter 6
Special kinds of company
Mutual trading companies
633    Mutual trading companies
Corporation Tax Bill xxxi
Insurance companies
634    Insurance companies
635    Creditor relationships: embedded derivatives which are options
636    Modifications of Chapter 5
Investment and venture capital trusts
637    Investment trusts: profits or losses of a capital nature
638    Venture capital trusts: profits or losses of a capital nature
Chapter 7
Chargeable gains arising in relation to derivative contracts
Introduction
639    Overview of Chapter
Some credits and debits not to be brought into account under Part 5
640    Credits and debits not to be brought into account under Part 5
Some derivative contracts to be taxed on a chargeable gains basis
641    Derivative contracts to be taxed on a chargeable gains basis
642    Exception from section 641
Derivative contracts to which sections 640 and 641 apply
643    Contracts relating to land or certain tangible movable property
644    Income to be left out of account in determining whether section 643 applies
645    Creditor relationships: embedded derivatives which are options
646    Exclusions from section 645
647    Meaning of certain expressions in section 645
648    Creditor relationships: embedded derivatives which are exactly tracking
contracts for differences
649    Meaning of certain expressions in section 648
650    Property based total return swaps
Some credits and debits not to be brought into account under Part 3 or 5
651    Credits and debits not to be brought into account under Part 3 or Part 5
Issuers of securities with embedded derivatives: deemed options
652    Introduction to sections 653 to 655
653    Shares issued or transferred as a result of exercise of deemed option
654    Payment instead of disposal on exercise of deemed option
655    Ceasing to be party to debtor relationship when deemed option not exercised
Issuers of securities with embedded derivatives: deemed contracts for differences
656    Introduction to section 658
657    Meaning of “exactly tracking contract” in section 656
Corporation Tax Bill xxxii
658    Chargeable gain or allowable loss treated as accruing
Interpretation
659    Meaning of “relevant credits” and “relevant debits”
Chapter 8
Further provision about chargeable gains and derivative contracts
Company ceasing to be party to certain contracts
660    Contract relating to holding in OEIC, unit trust or offshore fund
661    Contract which becomes derivative contract
Contracts ceasing to be derivative contracts
662    Contracts ceasing to be derivative contracts
Carry back of net losses on certain derivative contracts
663    Contracts to which section 641 applies
664    Meaning of certain expressions in section 663
Issuers of securities with embedded derivatives: equity instruments
665    Introduction to section 666
666    Allowable loss treated as accruing
Treatment of shares acquired in certain circumstances
667    Shares acquired on exercise of non-embedded option
668    Shares acquired on running of future to delivery
669    Meaning of G and L in sections 667 and 668
Treatment of net gains and losses on exercise of option
670    Treatment of net gains and losses on exercise of option
671    Meaning of G, L and CV in section 670
Treatment of net gains and losses on disposal of certain embedded derivatives
672    Treatment of net gains and losses on disposal of certain embedded
derivatives
673    Meaning of G, L and CV in section 672
Chapter 9
European cross-border transfers of business
Introduction
674    Introduction to Chapter
Corporation Tax Bill xxxiii
Transfers of derivative contracts at notional carrying value
675    Transfer of derivative contract at notional carrying value
676    Transferor using fair value accounting
Exception for tax avoidance cases and clearances
677    Tax avoidance etc
678    Procedure on application for clearance
679    Decision on application for clearance
Transparent entities
680    Disapplication of Chapter where transparent entities involved
Interpretation
681    Interpretation
Chapter 10
European cross-border mergers
Introduction
682    Introduction to Chapter
683    Meaning of “the transferee” and “transferor”
Transfers of derivative contracts at notional carrying value
684    Transfer of derivative contract at notional carrying value
685    Transferor using fair value accounting
Exception for tax avoidance cases and clearances
686    Tax avoidance etc
Transparent entities
687    Disapplication of Chapter where transparent entities involved
Interpretation
688    Interpretation
Chapter 11
Tax avoidance
Introduction
689    Overview of Chapter
Corporation Tax Bill xxxiv
Unallowable purposes
690    Derivative contracts for unallowable purposes
691    Meaning of “unallowable purpose”
692    Allowance of accumulated net losses
Transactions not at arm’s length
693    Bringing into account adjustments under Schedule 28AA to ICTA
694    Exchange gains and losses
695    Transfers of value to connected companies
Transactions with non-UK residents
696    Derivative contracts with non-UK residents
697    Exceptions to section 696
Disposals for consideration not fully recognised by accounting practice
698    Disposals for consideration not fully recognised by accounting practice
Chapter 12
Priority rules
699    Priority of this Part for corporation tax purposes
700    Relationship of this Part to Part 5: loan relationships
Chapter 13
General and supplementary provisions
Power to amend certain provisions
701    Power to amend some provisions
Other general definitions
702    “Carrying value”
703    “Chargeable asset”
704    “Creditor relationship” and “debtor relationship”
705    Expressions relating to exchange gains and losses
706    “Excluded body”
707    “Hedging relationship”
708    “Plain vanilla contract”
709    “Securities house”
710    Other definitions
Corporation Tax Bill xxxv
Part 8
Intangible fixed assets
Chapter 1
Introduction
Introductory
711    Overview of Part
Basic definitions
712    “Intangible asset”
713    “Intangible fixed asset”
714    “Royalty”
Goodwill
715    Application of this Part to goodwill
Accounting rules and definitions
716    “Recognised” amounts and “GAAP-compliant accounts”
717    Companies without GAAP-compliant accounts
718    GAAP-compliant accounts: reference to consolidated group accounts
719    Accounting value
Chapter 2
Credits in respect of intangible fixed assets
720    Introduction
721    Receipts recognised as they accrue
722    Receipts in respect of royalties so far as not dealt with under section 721
723    Revaluation
724    Negative goodwill
725    Reversal of previous accounting loss
Chapter 3
Debits in respect of intangible fixed assets
726    Introduction
727    References to expenditure on an asset
728    Expenditure written off as it is incurred
729    Writing down on accounting basis
730    Writing down at fixed rate: election for fixed-rate basis
731    Writing down at fixed rate: calculation
732    Reversal of previous accounting gain

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