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Vol 23 No 5 May/June 2018

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This book is now Out of Print.
A new edition has been published, the details can be seen here:
Taxation of Loan Relationship and Derivative Contracts 10th ed isbn 9781780438917

Taxation of Loan Relationships and Derivative Contracts 9th ed

ISBN13: 9781845923037
New Edition ISBN: 9781780438917
Previous Edition ISBN: 9781845921873
Published: June 2012
Publisher: Bloomsbury Professional
Country of Publication: UK
Format: Paperback
Price: Out of print

Taxation of Loan Relationships and Derivative Contracts 9th ed has been comprehensively revised, updated and re-written in light of the Tax Law Rewrite and recent major changes that have significantly affected the day-to-day work of a corporate tax adviser.

The new edition of this well-established work offers comprehensive coverage of all aspects of the taxation of loan relationships and derivative contracts, with particular emphasis placed on providing worked examples and planning guidance.

It covers:-

  • retrospective provisions in Finance Bill 2012 dealing with debt buy-backs
  • loan relationships, derivative contracts, securities taxation
  • IAS 32/39 and FRS 25/26
  • loan relationships under IAS
  • impairment losses and connected company rules
  • the derivative contracts rules
  • bifurcation of convertibles
  • transfer pricing- domestic and international
  • the disregard rules on tax hedging
  • the worldwide debt cap
  • matching and functional currencies
  • reorganisations, reconstructions and mergers
  • new stock lending and repo rules
  • anti-avoidance rules
David Southern is a practising barrister at Temple Tax Chambers, 3 Temple Gardens, and is Visiting Professor and Director of the School of Tax Law at the Centre for Commercial Law Studies, Queen Mary, University of London.

1. Taxation of Finance
2. Accounting under IFRS and Modified UK GAAP
3. The Scheme of Legislation
4. Loan Relationships: Scope and Definition
5. Loan Relationships: General Computational Provisions
6. Loan Relationships: Special Computational Provisions
7. Impairment Losses
8. Foreign Exchange Gains and Losses
9. Interest
10. Securities
11. Reorganisations, Acquisitions and Disposals
12. Special Companies
13. Derivative Contracts - Definition and Scope
14. Derivative Contracts - Measurement of Profits
15. Embedded Derivatives
16. Hedging and Deferral
17. Worldwide Debt Cap
18. Transfer Pricing
19. Stock Lending and Repos
20. International Aspects
Appendix 1
Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2004