SCHEDULE 20 Tax Mismatch Schemes
Finance Act 2013 (2013 c 29) | Legislation

SCHEDULE 20 Tax Mismatch Schemes

Section 42

1

CTA 2010 is amended in accordance with paragraphs 2 to 4.

2

In section 1(4) (overview of Act), after paragraph (j) insert—

“(ja)     tax mismatch schemes (see Part 21BA),â€.

3

After Part 21B insert—

“Part 21BA
Tax Mismatch Schemes
938O Losses and profits from tax mismatch scheme to be disregarded

(1)     This section applies to a company that is (at any time) a party to a tax mismatch scheme.

(2)     No scheme loss or profit made by the company in any accounting period in relation to the scheme is to be brought into account as a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts).

(3)     An amount that would, apart from this section, be brought into account for the purposes of Part 5 or 7 of that Act as respects any matter—

(a)     is treated, for the purposes of section 464(1) or (as the case may be) 699(1) of that Act (priority of Part 5 or 7 for corporation tax purposes), as if it were so brought into account, and

(b)     accordingly, may

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